Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
The HC held that electronic communication of the impugned order (email) satisfied service requirements under Section 169 CGST and that delay in uploading Form DRC-07 or portal posting did not render the order time-barred. The court found prima facie service by email sufficient despite multiple noticees and considerable ITC allegations. The impugned order was declared appealable; the Petitioner was permitted to file statutory appeals under Section 107 CGST by 30 September 2025 with the requisite pre-deposit. If filed within that period, the appeals shall not be dismissed on limitation grounds and shall be adjudicated on merits. Petition disposed.
The HC held that electronic communication of the impugned order (email) satisfied service requirements under Section 169 CGST and that delay in uploading Form DRC-07 or portal posting did not render the order time-barred. The court found prima facie service by email sufficient despite multiple noticees and considerable ITC allegations. The impugned order was declared appealable; the Petitioner was permitted to file statutory appeals under Section 107 CGST by 30 September 2025 with the requisite pre-deposit. If filed within that period, the appeals shall not be dismissed on limitation grounds and shall be adjudicated on merits. Petition disposed.
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TaxTMI 
TaxTMI 
of 4891 
