Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
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...
The HC dismissed the writ petition under Articles 226 and 227 for want of maintainability, holding that the petitioner failed to demonstrate sufficient cause for inordinate delay and unjustifiably bypassed the statutory alternative remedy to challenge the impugned order dated 17 August 2024. Allegations concerning excess input tax credit in GSTR-3B vis-Ã -vis GSTR-2A did not justify invocation of discretionary writ jurisdiction absent promptness or exceptional circumstances. Applying established parameters restricting exercise of Article 226 discretion, the Court declined to exercise relief against an assessment/order capable of statutory challenge and accordingly dismissed the petition.
The HC dismissed the writ petition under Articles 226 and 227 for want of maintainability, holding that the petitioner failed to demonstrate sufficient cause for inordinate delay and unjustifiably bypassed the statutory alternative remedy to challenge the impugned order dated 17 August 2024. Allegations concerning excess input tax credit in GSTR-3B vis-Ã -vis GSTR-2A did not justify invocation of discretionary writ jurisdiction absent promptness or exceptional circumstances. Applying established parameters restricting exercise of Article 226 discretion, the Court declined to exercise relief against an assessment/order capable of statutory challenge and accordingly dismissed the petition.
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