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...
HC quashed tax demand order under GST Act due to procedural irregularities in notice service. Petitioner claimed no awareness of notices or orders, preventing timely response within limitation period. Court found merit in petitioner's contention that order was not visible under system's "view notices and orders" tab, constituting violation of natural justice principles. Given that disputed amount was already deposited with State Government, HC directed treating impugned order as final notice, granting petitioner two weeks to submit written reply instead of relegating to statutory remedy. Matter resolved considering procedural fairness and existing tax deposit.
HC quashed tax demand order under GST Act due to procedural irregularities in notice service. Petitioner claimed no awareness of notices or orders, preventing timely response within limitation period. Court found merit in petitioner's contention that order was not visible under system's "view notices and orders" tab, constituting violation of natural justice principles. Given that disputed amount was already deposited with State Government, HC directed treating impugned order as final notice, granting petitioner two weeks to submit written reply instead of relegating to statutory remedy. Matter resolved considering procedural fairness and existing tax deposit.
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