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...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
GST assessment and rectification orders are subject to the statutory appellate mechanism, requiring exhaustion of that alternative remedy before a writ challenge is directly entertained. Where a GST demand and rejection of a rectification application were challenged without first filing an appeal, the writ petition was dismissed on that ground. Liberty was granted to file the statutory appeal within 30 days; if filed within that period, it must be entertained without a limitation objection and decided on merits. All substantive contentions remain open in the appellate proceedings.
GST assessment and rectification orders are subject to the statutory appellate mechanism, requiring exhaustion of that alternative remedy before a writ challenge is directly entertained. Where a GST demand and rejection of a rectification application were challenged without first filing an appeal, the writ petition was dismissed on that ground. Liberty was granted to file the statutory appeal within 30 days; if filed within that period, it must be entertained without a limitation objection and decided on merits. All substantive contentions remain open in the appellate proceedings.
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