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...
GST refund provisions for unutilised input tax credit do not restrict refund applications to suppliers making supplies to SEZ units. The relevant refund rule identifies suppliers as one category of applicants but does not exclude an SEZ unit from claiming its own refund. Reading such a restriction into the statutory scheme would impermissibly add a limiting condition. SEZ units are therefore entitled to have eligible refund claims processed under the GST refund framework, and orders rejecting the claim on that restrictive basis were set aside.
GST refund provisions for unutilised input tax credit do not restrict refund applications to suppliers making supplies to SEZ units. The relevant refund rule identifies suppliers as one category of applicants but does not exclude an SEZ unit from claiming its own refund. Reading such a restriction into the statutory scheme would impermissibly add a limiting condition. SEZ units are therefore entitled to have eligible refund claims processed under the GST refund framework, and orders rejecting the claim on that restrictive basis were set aside.
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