Reassessment for unreturned property sales survives where transfer information, non-filing, and unsupported exemption claims establish a prima facie l...
Profit-element taxation limits additions for unaccounted flat-sale receipts and grey-market purchases, while reliable search records support partial a...
Non-participating bidders cannot disturb concluded liquidation sales on speculative prejudice, while costs for such challenges must remain proportiona...
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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