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...
The HC held that the retrospective extension of the time limit to avail input tax credit under sub-section (4) of Section 16 of the CGST Act, as per the Ministry of Finance circular dated 15-10-2024, permits taxpayers to seek rectification of orders passed under Sections 73, 74, 107, or 108 of the CGST Act regarding wrongful input tax credit claims. Pursuant to the special procedure under Section 148, notified on 8-10-2024, rectification applications may be filed within six months from 15-10-2024, i.e., until 15-4-2025. The petitioner was granted leave to file such an application, and the petition was accordingly disposed of.
The HC held that the retrospective extension of the time limit to avail input tax credit under sub-section (4) of Section 16 of the CGST Act, as per the Ministry of Finance circular dated 15-10-2024, permits taxpayers to seek rectification of orders passed under Sections 73, 74, 107, or 108 of the CGST Act regarding wrongful input tax credit claims. Pursuant to the special procedure under Section 148, notified on 8-10-2024, rectification applications may be filed within six months from 15-10-2024, i.e., until 15-4-2025. The petitioner was granted leave to file such an application, and the petition was accordingly disposed of.
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