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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Availability of an efficacious statutory appeal materially constrains Article 226 writ jurisdiction in GST adjudication. Once show-cause proceedings culminate in an Order-in-Original, disputes over overlapping State and Central input tax credit proceedings, factual and evidentiary material, and a multi-year notice should ordinarily be examined on appeal. A statutory pre-deposit obligation and the earlier filing of a writ during pending notice proceedings do not alone justify bypassing that remedy. Absent patent jurisdictional infirmity, appellate review remains available on all permissible grounds; the writ petition was dismissed with liberty to appeal.
Availability of an efficacious statutory appeal materially constrains Article 226 writ jurisdiction in GST adjudication. Once show-cause proceedings culminate in an Order-in-Original, disputes over overlapping State and Central input tax credit proceedings, factual and evidentiary material, and a multi-year notice should ordinarily be examined on appeal. A statutory pre-deposit obligation and the earlier filing of a writ during pending notice proceedings do not alone justify bypassing that remedy. Absent patent jurisdictional infirmity, appellate review remains available on all permissible grounds; the writ petition was dismissed with liberty to appeal.
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