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...
HC set aside the impugned orders and quashed the appellate rejection based solely on delay, holding that the petitioner was entitled to a reasonable opportunity to adduce material evidence concerning GST exemption on specified rice transactions. The court directed the petitioner to produce invoices and corroborative evidence within two months and ordered the competent authority to schedule an oral hearing, consider the newly produced material, and pass a fresh speaking order within four months. The matter is remitted for fresh adjudication on merits limited to the exemption claim; petition allowed and prior orders dated 15.04.2025, 27.04.2024 and 28.04.2024 set aside.
HC set aside the impugned orders and quashed the appellate rejection based solely on delay, holding that the petitioner was entitled to a reasonable opportunity to adduce material evidence concerning GST exemption on specified rice transactions. The court directed the petitioner to produce invoices and corroborative evidence within two months and ordered the competent authority to schedule an oral hearing, consider the newly produced material, and pass a fresh speaking order within four months. The matter is remitted for fresh adjudication on merits limited to the exemption claim; petition allowed and prior orders dated 15.04.2025, 27.04.2024 and 28.04.2024 set aside.
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