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...
Denial of Input Tax Credit (ITC) - Proof of movement of Goods (E-way bill) not produced - The High court acknowledges that the petitioner submitted original tax invoices, ledger accounts, bank statements, and relevant GSTR returns to support their position. However, they did not provide e-way bills, lorry receipts, or weighment slips to establish the actual movement of goods. The court notes that while the tax proposal was confirmed largely due to lack of proof of actual movement of goods, the documents submitted by the petitioner, including bank statements and GSTR 2A, indicated the availability of ITC. Thus, it deems it appropriate to provide the petitioner with an opportunity to produce additional documents to prove actual movement of goods. Matter restored back.
Denial of Input Tax Credit (ITC) - Proof of movement of Goods (E-way bill) not produced - The High court acknowledges that the petitioner submitted original tax invoices, ledger accounts, bank statements, and relevant GSTR returns to support their position. However, they did not provide e-way bills, lorry receipts, or weighment slips to establish the actual movement of goods. The court notes that while the tax proposal was confirmed largely due to lack of proof of actual movement of goods, the documents submitted by the petitioner, including bank statements and GSTR 2A, indicated the availability of ITC. Thus, it deems it appropriate to provide the petitioner with an opportunity to produce additional documents to prove actual movement of goods. Matter restored back.
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