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 and declined to interfere with the impugned assessment orders, which remain effective until set aside by a court or competent authority. The court held that s.168 CGST confers only a power to issue binding instructions to tax authorities; non-compliance renders consequent orders invalid but not void ab initio. Consequently, declaration of invalidity requires adjudication by an appropriate forum, which must also consider laches. The HC rejected claims of non-service via the GST portal and refused condonation of delay, finding the statutory portal service method adequate; anonymous petitioners' asserted unawareness of portal service did not justify relief.
The HC dismissed the petition and declined to interfere with the impugned assessment orders, which remain effective until set aside by a court or competent authority. The court held that s.168 CGST confers only a power to issue binding instructions to tax authorities; non-compliance renders consequent orders invalid but not void ab initio. Consequently, declaration of invalidity requires adjudication by an appropriate forum, which must also consider laches. The HC rejected claims of non-service via the GST portal and refused condonation of delay, finding the statutory portal service method adequate; anonymous petitioners' asserted unawareness of portal service did not justify relief.
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TaxTMI 
TaxTMI 
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