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 found a breach of natural justice for failure of service of show-cause notices (issued 24 Sept 2023 and 5 Dec 2025) which were uploaded to the GST portal's "Additional Notices Tab" but not brought to the petitioner's attention prior to portal visibility changes on 16 Jan 2024. The impugned orders are set aside for want of proper service and denial of opportunity to be heard. The matter is remanded to the adjudicating authority for fresh adjudication. The petitioner is granted leave to file a reply to the impugned SCNs by 30 Sept 2025. The petition is disposed of subject to these directions.
The HC found a breach of natural justice for failure of service of show-cause notices (issued 24 Sept 2023 and 5 Dec 2025) which were uploaded to the GST portal's "Additional Notices Tab" but not brought to the petitioner's attention prior to portal visibility changes on 16 Jan 2024. The impugned orders are set aside for want of proper service and denial of opportunity to be heard. The matter is remanded to the adjudicating authority for fresh adjudication. The petitioner is granted leave to file a reply to the impugned SCNs by 30 Sept 2025. The petition is disposed of subject to these directions.
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