Personal liberty safeguards restrict arrest after court-directed GST appearance, requiring interim release where authorities overreach pending proceed...
Alternative statutory remedy and delay bar GST writ challenges despite pending rectification, while distinct subject matter permits parallel proceedin...
Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
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Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Revisionary jurisdiction for inadequate inquiry into TDS on commission and brokerage expenditure arises where the Assessing Officer merely calls for TDS details without examining a material mismatch between financial-statement expenditure and TDS reporting. A substantial increase in expenditure and a claim that amounts retained by franchisees constituted discounts rather than commission require specific examination of contractual arrangements, accounting treatment and TDS liability. Failure to conduct that inquiry may render an assessment erroneous and prejudicial to Revenue interests, rather than reflecting a prohibited change of opinion. The revisionary order was sustained, leaving the expenditure's nature and tax consequences for fresh assessment after giving the assessee an opportunity to respond.
Revisionary jurisdiction for inadequate inquiry into TDS on commission and brokerage expenditure arises where the Assessing Officer merely calls for TDS details without examining a material mismatch between financial-statement expenditure and TDS reporting. A substantial increase in expenditure and a claim that amounts retained by franchisees constituted discounts rather than commission require specific examination of contractual arrangements, accounting treatment and TDS liability. Failure to conduct that inquiry may render an assessment erroneous and prejudicial to Revenue interests, rather than reflecting a prohibited change of opinion. The revisionary order was sustained, leaving the expenditure's nature and tax consequences for fresh assessment after giving the assessee an opportunity to respond.
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