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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Proceedings under the CGST Act, 2017 encompass not just judicial proceedings but also assessment, audit, detention/seizure/release of goods and conveyances, even if they do not culminate in a show cause notice. Investigation or inquiry initiated to safeguard government revenue qualifies as proceedings. The applicant's contention that inquiry/investigation does not constitute proceedings is misconceived. Since investigation by DGGI predated the applicant's advance ruling application on the same issue, the application is liable for rejection under the first proviso to Section 98(2) of the CGST/TNGST Acts, 2017. Consequently, the advance ruling application is rejected.
Proceedings under the CGST Act, 2017 encompass not just judicial proceedings but also assessment, audit, detention/seizure/release of goods and conveyances, even if they do not culminate in a show cause notice. Investigation or inquiry initiated to safeguard government revenue qualifies as proceedings. The applicant's contention that inquiry/investigation does not constitute proceedings is misconceived. Since investigation by DGGI predated the applicant's advance ruling application on the same issue, the application is liable for rejection under the first proviso to Section 98(2) of the CGST/TNGST Acts, 2017. Consequently, the advance ruling application is rejected.
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