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...
Violation of principles of natural justice - no opportunity of personal hearing granted - High court highlighted the provision u/s 75(4) of the CGST/MGST Act, which mandates an opportunity for a hearing to be granted either upon request from the person chargeable with tax or penalty or in cases where an adverse decision is contemplated against such a person. The court found that even though the petitioner did not request a personal hearing, the authority was obligated to offer one before making an adverse decision.
Violation of principles of natural justice - no opportunity of personal hearing granted - High court highlighted the provision u/s 75(4) of the CGST/MGST Act, which mandates an opportunity for a hearing to be granted either upon request from the person chargeable with tax or penalty or in cases where an adverse decision is contemplated against such a person. The court found that even though the petitioner did not request a personal hearing, the authority was obligated to offer one before making an adverse decision.
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