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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Departmental GST appeals below the prescribed monetary limit require the Revenue to identify and establish a specified exception to the binding litigation-management policy. A bare assertion that the Commissioner approved an appeal does not establish a case-specific, reasoned exercise of residual discretion or satisfy conditions governing the right of appeal. Maintainability must be determined before tax merits. Without an established exception, an appeal below the threshold is not maintainable and the underlying tax merits are not examined.
Departmental GST appeals below the prescribed monetary limit require the Revenue to identify and establish a specified exception to the binding litigation-management policy. A bare assertion that the Commissioner approved an appeal does not establish a case-specific, reasoned exercise of residual discretion or satisfy conditions governing the right of appeal. Maintainability must be determined before tax merits. Without an established exception, an appeal below the threshold is not maintainable and the underlying tax merits are not examined.
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