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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The HC set aside the impugned penalty orders and their common summary in Form GST DRC-07 (dated 06.06.2025) on grounds of procedural infirmity-absence of the assessing officer's digital signature and omission of a DIN-finding such defects render the orders invalid and breach principles of natural justice. The writ petition was disposed of, with the Court granting the Respondent liberty to initiate fresh assessment proceedings, subject to issuance of proper notice and execution of the resultant orders bearing an assigned signature and DIN. No costs were awarded.
The HC set aside the impugned penalty orders and their common summary in Form GST DRC-07 (dated 06.06.2025) on grounds of procedural infirmity-absence of the assessing officer's digital signature and omission of a DIN-finding such defects render the orders invalid and breach principles of natural justice. The writ petition was disposed of, with the Court granting the Respondent liberty to initiate fresh assessment proceedings, subject to issuance of proper notice and execution of the resultant orders bearing an assigned signature and DIN. No costs were awarded.
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