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...
Rule 117(4)(b)(iii) of the CGST Rules was challenged as ultra vires Section 140(3) of the CGST Act and violative of Article 14 of the Constitution. The court held that the petitioner has the right to avail transitional credit legally due, and the authorities should permit rectification of TRAN-1/TRAN-2 by making necessary software changes. The respondents were directed to allow the petitioner to file rectified TRAN-1 with correct details and TRAN-2 within eight weeks to avail transitional credit. The impugned show-cause notice was quashed, and the petition was allowed.
Rule 117(4)(b)(iii) of the CGST Rules was challenged as ultra vires Section 140(3) of the CGST Act and violative of Article 14 of the Constitution. The court held that the petitioner has the right to avail transitional credit legally due, and the authorities should permit rectification of TRAN-1/TRAN-2 by making necessary software changes. The respondents were directed to allow the petitioner to file rectified TRAN-1 with correct details and TRAN-2 within eight weeks to avail transitional credit. The impugned show-cause notice was quashed, and the petition was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
