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 of unutilised CENVAT Credit - Once it is held that the appellant has rightly taken cenvat credit and the same is lying in their books un-utilised as on 30.06.2017, when the provisions of CGST Act (GST regime) was implemented w.e.f. 01.07.2017, and thus if the appellant has not taken the un-utilised cenvat credit to the GST regime by filing form TRAN-1, they are eligible to refund of the un-utilised credit in terms of the transitional provision under Section 142(2) and (6) of the CGST Act - AT
Refund of unutilised CENVAT Credit - Once it is held that the appellant has rightly taken cenvat credit and the same is lying in their books un-utilised as on 30.06.2017, when the provisions of CGST Act (GST regime) was implemented w.e.f. 01.07.2017, and thus if the appellant has not taken the un-utilised cenvat credit to the GST regime by filing form TRAN-1, they are eligible to refund of the un-utilised credit in terms of the transitional provision under Section 142(2) and (6) of the CGST Act - AT
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