Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Levy of penalty - no E-Way Bill, invoice and bilty were present in the vehicle carrying the goods - onus to prove (shifting burden) - The High court held that the petitioner failed to rebut the presumption of tax evasion since they could not explain the absence of the invoice and E-Way Bill. Thus, the penalty imposed is upheld, emphasizing that penalties act as deterrents to tax evasion.
Levy of penalty - no E-Way Bill, invoice and bilty were present in the vehicle carrying the goods - onus to prove (shifting burden) - The High court held that the petitioner failed to rebut the presumption of tax evasion since they could not explain the absence of the invoice and E-Way Bill. Thus, the penalty imposed is upheld, emphasizing that penalties act as deterrents to tax evasion.
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