Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
The HC dismissed the petition challenging consolidation of a single SCN spanning multiple tax years concerning alleged fraudulent availing of Input Tax Credit exceeding Rs.89 crores, holding that consolidation is permissible where primary allegation is fraudulent ITC. The court observed the impugned order is appealable under Section 107 of the CGST Act, 2017, and accordingly disposed of the petition while granting the Petitioner liberty to file an appeal by 30 September 2025 subject to compliance with requisite pre-deposit conditions. The disposal is without prejudice to the appellate forum's adjudication on merits and any statutory or equitable defenses available to the parties.
The HC dismissed the petition challenging consolidation of a single SCN spanning multiple tax years concerning alleged fraudulent availing of Input Tax Credit exceeding Rs.89 crores, holding that consolidation is permissible where primary allegation is fraudulent ITC. The court observed the impugned order is appealable under Section 107 of the CGST Act, 2017, and accordingly disposed of the petition while granting the Petitioner liberty to file an appeal by 30 September 2025 subject to compliance with requisite pre-deposit conditions. The disposal is without prejudice to the appellate forum's adjudication on merits and any statutory or equitable defenses available to the parties.
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TaxTMI 
TaxTMI 
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