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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Reasoned appellate orders are required by natural justice: common GST appellate orders confirming demands were invalid because they gave only a general conclusion without addressing material appeal grounds, cited judicial authorities, or each appellant's distinct contentions. The failure to give cogent reasons constituted a failure to exercise appellate jurisdiction. Objections concerning show cause notices, availability of relied-upon documents, and effective personal hearing in original proceedings also required consideration. The Tribunal set aside the appellate and original orders and remitted the matters for fresh adjudication after providing relied-upon documents, allowing replies and effective hearings, and issuing reasoned orders.
Reasoned appellate orders are required by natural justice: common GST appellate orders confirming demands were invalid because they gave only a general conclusion without addressing material appeal grounds, cited judicial authorities, or each appellant's distinct contentions. The failure to give cogent reasons constituted a failure to exercise appellate jurisdiction. Objections concerning show cause notices, availability of relied-upon documents, and effective personal hearing in original proceedings also required consideration. The Tribunal set aside the appellate and original orders and remitted the matters for fresh adjudication after providing relied-upon documents, allowing replies and effective hearings, and issuing reasoned orders.
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