Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Mandatory authentication under Rule 26(3) requires every electronic GST notice and adjudication order to bear a digital signature, e-signature, or another notified verification mode. An officer's portal login authenticates access only; it does not authenticate or attribute a document's contents. Electronic documents issued without a signature or notified authentication mode lack legal existence, and the defect is jurisdictional rather than curable. The unsigned show cause notice, adjudication order, and consequential recovery action were set aside, while fresh proceedings remained available in accordance with law. A statutory appeal does not bar writ jurisdiction where the challenged order lacks legal existence.
Mandatory authentication under Rule 26(3) requires every electronic GST notice and adjudication order to bear a digital signature, e-signature, or another notified verification mode. An officer's portal login authenticates access only; it does not authenticate or attribute a document's contents. Electronic documents issued without a signature or notified authentication mode lack legal existence, and the defect is jurisdictional rather than curable. The unsigned show cause notice, adjudication order, and consequential recovery action were set aside, while fresh proceedings remained available in accordance with law. A statutory appeal does not bar writ jurisdiction where the challenged order lacks legal existence.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
