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...
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Interest and penalty liability - Petitioner discharged GST liability before issuance of SCN - Petitioner sought permission to approach the appellate authority by way of statutory appeal. - While the respondent highlights the failure of the petitioner to remit tax on outward supplies, the court considers the circumstances surrounding the case. Given that the tax liability was settled in 2019 and 100% penalty was imposed, the court deems it just and appropriate to permit the petitioner to file a statutory appeal. However, since the time limit for filing the appeal has expired, the petitioner is required to remit a specified amount as a condition for filing the appeal.
Interest and penalty liability - Petitioner discharged GST liability before issuance of SCN - Petitioner sought permission to approach the appellate authority by way of statutory appeal. - While the respondent highlights the failure of the petitioner to remit tax on outward supplies, the court considers the circumstances surrounding the case. Given that the tax liability was settled in 2019 and 100% penalty was imposed, the court deems it just and appropriate to permit the petitioner to file a statutory appeal. However, since the time limit for filing the appeal has expired, the petitioner is required to remit a specified amount as a condition for filing the appeal.
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