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...
HC held that the Adjudicating Authority must reconsider the GST assessment by applying Circular No. 199/11/2023-GST and recent precedent. The court found the original order did not properly consider the circular's provisions regarding cross-charged expenses. The Adjudicating Authority is directed to provide a fresh hearing to the petitioner and issue a new order consistent with the circular's guidelines, potentially nullifying the tax liability. The court referenced the Metal One Corporation judgment, which suggested no tax liability where no invoices were generated. Petition disposed of with directions for re-evaluation.
HC held that the Adjudicating Authority must reconsider the GST assessment by applying Circular No. 199/11/2023-GST and recent precedent. The court found the original order did not properly consider the circular's provisions regarding cross-charged expenses. The Adjudicating Authority is directed to provide a fresh hearing to the petitioner and issue a new order consistent with the circular's guidelines, potentially nullifying the tax liability. The court referenced the Metal One Corporation judgment, which suggested no tax liability where no invoices were generated. Petition disposed of with directions for re-evaluation.
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