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...
The HC upheld the levy of IGST and penalty for detention of goods due to non-generation of Part B of the E-way bill, despite the consignment being accompanied by a tax invoice with a Letter of Undertaking number, consignment note, and letter of credit. The court affirmed that under Rule 138 of the MPGST Rules, both Part A and Part B of FORM GST EWB-01 must be generated electronically before the movement of goods exceeding Rs. 50,000 in value. The absence of Part B invalidated the E-way bill, rendering the transportation unauthorized. The court held that generation of Part B is a mandatory statutory requirement to validate the movement, especially for export consignments. Consequently, the impugned order imposing tax and penalty was found proper, and the petition was dismissed.
The HC upheld the levy of IGST and penalty for detention of goods due to non-generation of Part B of the E-way bill, despite the consignment being accompanied by a tax invoice with a Letter of Undertaking number, consignment note, and letter of credit. The court affirmed that under Rule 138 of the MPGST Rules, both Part A and Part B of FORM GST EWB-01 must be generated electronically before the movement of goods exceeding Rs. 50,000 in value. The absence of Part B invalidated the E-way bill, rendering the transportation unauthorized. The court held that generation of Part B is a mandatory statutory requirement to validate the movement, especially for export consignments. Consequently, the impugned order imposing tax and penalty was found proper, and the petition was dismissed.
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TaxTMI 
TaxTMI 
of 4918 
