Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
SC held that issuance of summons does not amount to the "initiation of any proceedings" under Section 6(2)(b) of the CGST Act; formal initiation occurs upon service of a show cause notice delineating the subject matter. The Court construed "subject matter" as the specific tax liability, deficiency or obligation framed in adjudicatory proceedings and held that overlapping or investigative acts (summons, search, seizure) do not ipso facto create identical subject matter attracting the bar in Section 6(2)(b). Section 6(2)(a) requires a proper officer issuing an order under the CGST Act to communicate a corresponding order to the State/UT counterpart to prevent multiplicity of proceedings. Petition disposed.
SC held that issuance of summons does not amount to the "initiation of any proceedings" under Section 6(2)(b) of the CGST Act; formal initiation occurs upon service of a show cause notice delineating the subject matter. The Court construed "subject matter" as the specific tax liability, deficiency or obligation framed in adjudicatory proceedings and held that overlapping or investigative acts (summons, search, seizure) do not ipso facto create identical subject matter attracting the bar in Section 6(2)(b). Section 6(2)(a) requires a proper officer issuing an order under the CGST Act to communicate a corresponding order to the State/UT counterpart to prevent multiplicity of proceedings. Petition disposed.
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TaxTMI 
TaxTMI 
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