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 set aside the impugned orders dated 18.02.2021, 28.10.2020, and 27.01.2021 passed by the respective respondents concerning revised refund claims barred by limitation under Notification No. 02/2019-CT. The court held that the applicability of the Apex Court's suo motu judgment, Circular No. 157/13/2021-GST, and Notification No. 13/2020 CT requires reconsideration. Consequently, all three matters were remanded to the First Appellate Authority for fresh adjudication in light of the recent legal developments. The writ petitions were disposed of accordingly, with liberty granted to the respondents to raise any grounds in future writ petitions or proceedings. The petition was allowed in part.
The HC set aside the impugned orders dated 18.02.2021, 28.10.2020, and 27.01.2021 passed by the respective respondents concerning revised refund claims barred by limitation under Notification No. 02/2019-CT. The court held that the applicability of the Apex Court's suo motu judgment, Circular No. 157/13/2021-GST, and Notification No. 13/2020 CT requires reconsideration. Consequently, all three matters were remanded to the First Appellate Authority for fresh adjudication in light of the recent legal developments. The writ petitions were disposed of accordingly, with liberty granted to the respondents to raise any grounds in future writ petitions or proceedings. The petition was allowed in part.
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