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 Respondent opted for GST at 5% without ITC as per Notification No. 03/2019-Central Tax (Rate) and reversed all available ITC pertaining to the financial years 2017-2018 and 2018-2019 from April 2019 onwards. The Respondent also reversed ITC availed due to delay in payments to suppliers beyond 180 days and excess ITC availed wrongly, resulting in negative credit during the post-GST period. The Respondent did not retain any ITC related to the 'Ireo Waterfront' project and reversed all ineligible ITC. Post-GST, no additional ITC benefit accrued to the Respondent for the 'Ireo Waterfront' project. Consequently, the provisions of Section 171(1) of the CGST Act, 2017 are not attracted, and the proceedings were dropped.
The Respondent opted for GST at 5% without ITC as per Notification No. 03/2019-Central Tax (Rate) and reversed all available ITC pertaining to the financial years 2017-2018 and 2018-2019 from April 2019 onwards. The Respondent also reversed ITC availed due to delay in payments to suppliers beyond 180 days and excess ITC availed wrongly, resulting in negative credit during the post-GST period. The Respondent did not retain any ITC related to the 'Ireo Waterfront' project and reversed all ineligible ITC. Post-GST, no additional ITC benefit accrued to the Respondent for the 'Ireo Waterfront' project. Consequently, the provisions of Section 171(1) of the CGST Act, 2017 are not attracted, and the proceedings were dropped.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
