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...
The petitioners sought transfer of unutilized input tax credit available in their ledgers as on 02.06.2014 to the AP GST regime. The court held that Section 56 of the Andhra Pradesh Reorganisation Act, 2014 deals with refund of excess tax collected, but is inapplicable to unutilized input tax credit, which is not excess tax paid. Consequently, the impugned demand orders in Form GST DRC-07 issued by the respondent were set aside, and the petition was allowed. The court clarified that the petitioners' only option was not to seek a refund, as Section 56 did not cover unutilized input tax credit.
The petitioners sought transfer of unutilized input tax credit available in their ledgers as on 02.06.2014 to the AP GST regime. The court held that Section 56 of the Andhra Pradesh Reorganisation Act, 2014 deals with refund of excess tax collected, but is inapplicable to unutilized input tax credit, which is not excess tax paid. Consequently, the impugned demand orders in Form GST DRC-07 issued by the respondent were set aside, and the petition was allowed. The court clarified that the petitioners' only option was not to seek a refund, as Section 56 did not cover unutilized input tax credit.
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