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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Transitional Input tax credit - availment of accumulated CENVAT by filing declaration Form TRAN-1 beyond the period provided under CGST Rules - Rule 117 is directory in nature, insofar as it prescribes the time-limit for transitioning of credit and therefore, the same would not result in the forfeiture of the rights, in case the credit is not availed within the period prescribed - the period of three years should be the guiding principle and thus a period of three years from the appointed date would be the maximum period for availing of such credit.
Transitional Input tax credit - availment of accumulated CENVAT by filing declaration Form TRAN-1 beyond the period provided under CGST Rules - Rule 117 is directory in nature, insofar as it prescribes the time-limit for transitioning of credit and therefore, the same would not result in the forfeiture of the rights, in case the credit is not availed within the period prescribed - the period of three years should be the guiding principle and thus a period of three years from the appointed date would be the maximum period for availing of such credit.
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