Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
Service of a GST show-cause notice solely through upload on the Common Portal may be inadequate where receipt is unacknowledged, no reply is filed, and the taxpayer lacks effective knowledge of the proceedings. Although the statutory limitation period binds the appellate authority, writ jurisdiction may address delay caused by circumstances beyond the taxpayer's control where refusing merits adjudication would cause grave injury or prejudice. In the stated circumstances, delay in filing the GST appeal against an input tax credit demand was condoned, the limitation-based dismissal was set aside, and the appellate authority was directed to decide the fresh appeal on merits without raising limitation.
Service of a GST show-cause notice solely through upload on the Common Portal may be inadequate where receipt is unacknowledged, no reply is filed, and the taxpayer lacks effective knowledge of the proceedings. Although the statutory limitation period binds the appellate authority, writ jurisdiction may address delay caused by circumstances beyond the taxpayer's control where refusing merits adjudication would cause grave injury or prejudice. In the stated circumstances, delay in filing the GST appeal against an input tax credit demand was condoned, the limitation-based dismissal was set aside, and the appellate authority was directed to decide the fresh appeal on merits without raising limitation.
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