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...
Refund - inverted tax structure - No inherent power can be inferred from the provision of Section 54(3) empowering the Central Government to provide for the lapsing of the unutilised ITC accumulated on account of the rate of tax on inputs being higher than the rate of tax on output supplies - Notification No.20/2018-C.T.(Rate) dated 26.07.2018, is ex-facie invalid and liable to be strike down as being without any authority of law
Refund - inverted tax structure - No inherent power can be inferred from the provision of Section 54(3) empowering the Central Government to provide for the lapsing of the unutilised ITC accumulated on account of the rate of tax on inputs being higher than the rate of tax on output supplies - Notification No.20/2018-C.T.(Rate) dated 26.07.2018, is ex-facie invalid and liable to be strike down as being without any authority of law
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