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...
Principles of natural justice violated due to vague summary notice merely citing risk of excess ITC availed by petitioner on account of GSTR mismatch. Order u/s 73 of CGST Act set aside as proper officer failed to consider detailed replies with supporting documents filed by petitioner, merely stating they were unsatisfactory without application of mind. Reference to audit observation erroneous as no audit conducted u/s 65. Impugned order quashed, show cause notice remitted to proper officer for re-adjudication. Petition disposed of by remand.
Principles of natural justice violated due to vague summary notice merely citing risk of excess ITC availed by petitioner on account of GSTR mismatch. Order u/s 73 of CGST Act set aside as proper officer failed to consider detailed replies with supporting documents filed by petitioner, merely stating they were unsatisfactory without application of mind. Reference to audit observation erroneous as no audit conducted u/s 65. Impugned order quashed, show cause notice remitted to proper officer for re-adjudication. Petition disposed of by remand.
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TaxTMI 
TaxTMI 
of 4918 
