Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Sections 73 and 74 of the CGST Act permit a common show cause notice covering multiple tax periods or financial years, as the expressions "for any period" and "such periods" do not impose a financial-year-specific bar. Financial-year references in the order-limitation provisions operate as separate limitation benchmarks for each demand component; consolidation cannot extend limitation or defeat period-wise objections. Section 74 requires disclosed material supporting fraud, wilful misstatement or suppression of facts to evade tax, and cannot be invoked merely because tax remains unpaid. Rule 142 and FORM GST DRC-01 regulate electronic notice communication without restricting consolidation. Notice-specific allegations, quantified demands, hearing rights, reasoned orders and limits on confirmation remain applicable.
Sections 73 and 74 of the CGST Act permit a common show cause notice covering multiple tax periods or financial years, as the expressions "for any period" and "such periods" do not impose a financial-year-specific bar. Financial-year references in the order-limitation provisions operate as separate limitation benchmarks for each demand component; consolidation cannot extend limitation or defeat period-wise objections. Section 74 requires disclosed material supporting fraud, wilful misstatement or suppression of facts to evade tax, and cannot be invoked merely because tax remains unpaid. Rule 142 and FORM GST DRC-01 regulate electronic notice communication without restricting consolidation. Notice-specific allegations, quantified demands, hearing rights, reasoned orders and limits on confirmation remain applicable.
Note: It is a system-generated summary and is for quick reference only.