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 SC upheld the High Court's determination that telecommunication towers do not constitute immovable property under Section 17(5)(d) of the CGST Act and are therefore eligible for input tax credit. The petitioners' contention that the towers are movable equipment was accepted, rejecting the Revenue's denial of credit. The SC declined to exercise its discretionary jurisdiction under Article 136, finding no merit in the Revenue's challenge. Consequently, the petition was dismissed, affirming the availability of input tax credit on telecommunication towers.
The SC upheld the High Court's determination that telecommunication towers do not constitute immovable property under Section 17(5)(d) of the CGST Act and are therefore eligible for input tax credit. The petitioners' contention that the towers are movable equipment was accepted, rejecting the Revenue's denial of credit. The SC declined to exercise its discretionary jurisdiction under Article 136, finding no merit in the Revenue's challenge. Consequently, the petition was dismissed, affirming the availability of input tax credit on telecommunication towers.
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