Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
The HC allowed the petition and quashed the composite SCN and resultant assessment order issued by the respondents insofar as they aggregate multiple financial years into a single proceeding. The court held Sections 73/74 (including sub-sections prescribing 3/5-year limitation) treat each financial year as a distinct tax period; therefore issuance of a single SCN spanning more than one financial year is impermissible and results in jurisdictional overreach rendering the order void ab initio. The HC directed that show-cause notices and assessments must be year-specific in accordance with the limitation scheme and statutory safeguards, and that annual returns delineate the applicable tax period for issuance of SCNs.
The HC allowed the petition and quashed the composite SCN and resultant assessment order issued by the respondents insofar as they aggregate multiple financial years into a single proceeding. The court held Sections 73/74 (including sub-sections prescribing 3/5-year limitation) treat each financial year as a distinct tax period; therefore issuance of a single SCN spanning more than one financial year is impermissible and results in jurisdictional overreach rendering the order void ab initio. The HC directed that show-cause notices and assessments must be year-specific in accordance with the limitation scheme and statutory safeguards, and that annual returns delineate the applicable tax period for issuance of SCNs.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
