Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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HC held that the petitioner's challenge to proceedings under Section 74 of the UPGST Act succeeds and the impugned orders are quashed. The court found that on the date of the transaction the supplier possessed valid registration and the supply was effected through a genuine billing channel characterized as a "Bill To Ship To" transaction with an e-way bill and vehicle identification; subsequent cancellation of the supplier's registration cannot retrospectively render the transaction bogus. In absence of any contradictory or adverse material on record to rebut the petitioner's factual pleas, no legal basis existed to sustain reversal of the input tax credit or other punitive measures. Petition allowed.
HC held that the petitioner's challenge to proceedings under Section 74 of the UPGST Act succeeds and the impugned orders are quashed. The court found that on the date of the transaction the supplier possessed valid registration and the supply was effected through a genuine billing channel characterized as a "Bill To Ship To" transaction with an e-way bill and vehicle identification; subsequent cancellation of the supplier's registration cannot retrospectively render the transaction bogus. In absence of any contradictory or adverse material on record to rebut the petitioner's factual pleas, no legal basis existed to sustain reversal of the input tax credit or other punitive measures. Petition allowed.
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