SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
HC held that the SCN issued under Section 73 of CGST Act was procedurally deficient as it failed to adequately address the assessee's reply to the final audit report regarding GSTR-9 and GSTR-1 mismatch. The Court emphasized that a valid SCN must specifically detail the authority's prima facie findings and reasoning for rejecting the assessee's explanations. Since the adjudicating authority merely acknowledged but did not analyze the assessee's submissions, the notice was deemed vague and prejudicial to the assessee's right of defense. Matter remanded for issuance of fresh SCN with proper reasoning addressing the assessee's October 21, 2024 reply and supporting documentation.
HC held that the SCN issued under Section 73 of CGST Act was procedurally deficient as it failed to adequately address the assessee's reply to the final audit report regarding GSTR-9 and GSTR-1 mismatch. The Court emphasized that a valid SCN must specifically detail the authority's prima facie findings and reasoning for rejecting the assessee's explanations. Since the adjudicating authority merely acknowledged but did not analyze the assessee's submissions, the notice was deemed vague and prejudicial to the assessee's right of defense. Matter remanded for issuance of fresh SCN with proper reasoning addressing the assessee's October 21, 2024 reply and supporting documentation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
