Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Penalty under Section 129(3) for alleged diversion of goods requires reliable evidence that the actual movement or delivery contravened GST law, even where valid invoices and e-way bills accompany the consignment. Vehicle proximity to another factory, discrepancies in a transport bilty, and the driver's statement do not, without corroboration, establish delivery to an undeclared recipient where the goods' description and quantity match the accompanying documents. Failure to provide GPS-camera footage relied on adversely may deny a fair opportunity to contest the allegation. The penalty orders were set aside and the penalty quashed.
Penalty under Section 129(3) for alleged diversion of goods requires reliable evidence that the actual movement or delivery contravened GST law, even where valid invoices and e-way bills accompany the consignment. Vehicle proximity to another factory, discrepancies in a transport bilty, and the driver's statement do not, without corroboration, establish delivery to an undeclared recipient where the goods' description and quantity match the accompanying documents. Failure to provide GPS-camera footage relied on adversely may deny a fair opportunity to contest the allegation. The penalty orders were set aside and the penalty quashed.
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