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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Proper-officer functions under the CGST Act may be assigned by circular to Central Tax Officers already appointed under a statutory notification, including demand-related functions allocated by monetary limits. Such assignment does not constitute delegation requiring a separate notification. Challenges to the circulars and to the officer's competence on that basis were rejected. A writ challenge to a GST demand order should ordinarily not proceed where an effective statutory appeal is available, unless a recognised exception applies. Where the authority considered the defence, examined documents and granted a personal hearing, reassessment of disputed material lies with the appellate authority. The demand challenge was therefore directed to the statutory appeal, with limitation protection for filing within 30 days.
Proper-officer functions under the CGST Act may be assigned by circular to Central Tax Officers already appointed under a statutory notification, including demand-related functions allocated by monetary limits. Such assignment does not constitute delegation requiring a separate notification. Challenges to the circulars and to the officer's competence on that basis were rejected. A writ challenge to a GST demand order should ordinarily not proceed where an effective statutory appeal is available, unless a recognised exception applies. Where the authority considered the defence, examined documents and granted a personal hearing, reassessment of disputed material lies with the appellate authority. The demand challenge was therefore directed to the statutory appeal, with limitation protection for filing within 30 days.
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