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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GST detention penalties under section 129 require a pleaded and established contravention of the Act or Rules. A show-cause notice must identify the defective documents and the precise legal provision allegedly breached; a vague allegation of diversion or unloading at an undeclared destination is insufficient. Reliance on inculpatory statements requires their disclosure, and an offered personal hearing and cross-examination opportunity must be genuinely afforded before adjudication. Appellate review must address material natural-justice objections and identify the statutory contravention rather than rely on route or invoicing observations alone.
GST detention penalties under section 129 require a pleaded and established contravention of the Act or Rules. A show-cause notice must identify the defective documents and the precise legal provision allegedly breached; a vague allegation of diversion or unloading at an undeclared destination is insufficient. Reliance on inculpatory statements requires their disclosure, and an offered personal hearing and cross-examination opportunity must be genuinely afforded before adjudication. Appellate review must address material natural-justice objections and identify the statutory contravention rather than rely on route or invoicing observations alone.
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