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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Violation of principles of natural justice occurred as petitioner's contentions were not considered - mismatch between petitioner's GSTR 3B returns and auto-populated GSTR 2A - third respondent failed to discuss petitioner's explanation for classifying product as farm tractor or record reasons for rejecting such explanation - regarding ITC mismatch, petitioner referred to issuance of invoices after financial year-end, but third respondent erroneously recorded petitioner's contention as ITC matching not being mandatory requirement - impugned order partly set aside concerning ITC mismatch and rate of tax difference/classification issues - third respondent directed to provide reasonable opportunity, including personal hearing, and issue fresh order within three months - petition disposed of.
Violation of principles of natural justice occurred as petitioner's contentions were not considered - mismatch between petitioner's GSTR 3B returns and auto-populated GSTR 2A - third respondent failed to discuss petitioner's explanation for classifying product as farm tractor or record reasons for rejecting such explanation - regarding ITC mismatch, petitioner referred to issuance of invoices after financial year-end, but third respondent erroneously recorded petitioner's contention as ITC matching not being mandatory requirement - impugned order partly set aside concerning ITC mismatch and rate of tax difference/classification issues - third respondent directed to provide reasonable opportunity, including personal hearing, and issue fresh order within three months - petition disposed of.
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