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...
Rectification petition - Validity Of Order passed - discrepancy between the GSTR 3B return - The petitioner contended that the discrepancy arose due to the belated filing of GSTR 1 by the supplier for one invoice and asserted their inability to upload a reply on the GST portal. Supporting documents, including certificates from the supplier and their Chartered Accountant, were submitted but not considered in the impugned order. - The High Court found that the non-consideration of these documents was significant and warranted interference with the order. Consequently, the court set aside the order and remanded the matter to the respondent for reconsideration.
Rectification petition - Validity Of Order passed - discrepancy between the GSTR 3B return - The petitioner contended that the discrepancy arose due to the belated filing of GSTR 1 by the supplier for one invoice and asserted their inability to upload a reply on the GST portal. Supporting documents, including certificates from the supplier and their Chartered Accountant, were submitted but not considered in the impugned order. - The High Court found that the non-consideration of these documents was significant and warranted interference with the order. Consequently, the court set aside the order and remanded the matter to the respondent for reconsideration.
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TaxTMI 
TaxTMI 
of 4918 
