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...
Validity of assessment order - Disparity in Returns - The High Court examined the case thoroughly. It noted that the entire tax liability stemmed from the disparity between the petitioner's GSTR 3B return and the auto-populated GSTR 2A return. Considering Circular No.183, which required obtaining a certificate from the supplier, the Court acknowledged that the petitioner eventually obtained the certificate, albeit belatedly. - The High Court, considering the submissions and evidence presented, set aside the impugned order and directed the respondent to provide the petitioner with a fair opportunity to address the tax demand.
Validity of assessment order - Disparity in Returns - The High Court examined the case thoroughly. It noted that the entire tax liability stemmed from the disparity between the petitioner's GSTR 3B return and the auto-populated GSTR 2A return. Considering Circular No.183, which required obtaining a certificate from the supplier, the Court acknowledged that the petitioner eventually obtained the certificate, albeit belatedly. - The High Court, considering the submissions and evidence presented, set aside the impugned order and directed the respondent to provide the petitioner with a fair opportunity to address the tax demand.
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TaxTMI 
TaxTMI 
of 4918 
