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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Provisional attachment of bank accounts under GST is a pre-emptive revenue-protection measure that ceases by operation of law one year after the attachment order. Continued freezing cannot rest on an expired attachment where no fresh provisional attachment order has been issued. Where account holders were not recipients of a later demand-cum-show cause notice, that notice did not provide a basis to maintain restrictions on their accounts. The lapsed attachments required the bank accounts to be defreezed and made operable upon production of a certified copy of the order.
Provisional attachment of bank accounts under GST is a pre-emptive revenue-protection measure that ceases by operation of law one year after the attachment order. Continued freezing cannot rest on an expired attachment where no fresh provisional attachment order has been issued. Where account holders were not recipients of a later demand-cum-show cause notice, that notice did not provide a basis to maintain restrictions on their accounts. The lapsed attachments required the bank accounts to be defreezed and made operable upon production of a certified copy of the order.
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