Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Parallel GST adjudication under Sections 73 and 74 for the same financial period was treated as incongruous once adjudication under Section 73 had concluded; the show cause notice, adjudication order and summary order under Section 74 were quashed. The ex parte Section 73 adjudication was also quashed and restored for fresh consideration because the taxpayer asserted that exemption documents and a reply could substantiate its position on the alleged mismatch or erroneous declaration. Reconsideration must occur after receiving the taxpayer's reply and supporting documents, while the merits of the exemption claim remain open.
Parallel GST adjudication under Sections 73 and 74 for the same financial period was treated as incongruous once adjudication under Section 73 had concluded; the show cause notice, adjudication order and summary order under Section 74 were quashed. The ex parte Section 73 adjudication was also quashed and restored for fresh consideration because the taxpayer asserted that exemption documents and a reply could substantiate its position on the alleged mismatch or erroneous declaration. Reconsideration must occur after receiving the taxpayer's reply and supporting documents, while the merits of the exemption claim remain open.
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