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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Electronic credit already recovered from a taxpayer's electronic credit ledger may be adjusted against the mandatory GST appellate pre-deposit where the recovered balance exceeds the required pre-deposit and the taxpayer seeks adjustment rather than refund. On that basis, dismissal of the GST appeal for non-payment of pre-deposit was quashed and the appeal restored for merits determination. The adjustment was permitted on the particular facts, with all merits contentions left open and without precedential effect.
Electronic credit already recovered from a taxpayer's electronic credit ledger may be adjusted against the mandatory GST appellate pre-deposit where the recovered balance exceeds the required pre-deposit and the taxpayer seeks adjustment rather than refund. On that basis, dismissal of the GST appeal for non-payment of pre-deposit was quashed and the appeal restored for merits determination. The adjustment was permitted on the particular facts, with all merits contentions left open and without precedential effect.
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