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 AT dismissed the DGAP's profiteering report and closed proceedings against the Respondent under Section 171, CGST Act, holding there is no admissible material establishing that the Respondent retained an unlawful benefit of input tax credit by failing to reduce prices. The AT noted mixed SKU price movements and absence of document evidence demonstrating overall profiteering; enquiries of 56 recipients showed 50 received ITC-related benefit, one was unregistered, and five were unreachable due to closure/liquidation/death. Consequently the DGAP's concluded profiteering amount was not accepted, no liability was fastened on the Respondent, and the complaint was thereby disposed.
The AT dismissed the DGAP's profiteering report and closed proceedings against the Respondent under Section 171, CGST Act, holding there is no admissible material establishing that the Respondent retained an unlawful benefit of input tax credit by failing to reduce prices. The AT noted mixed SKU price movements and absence of document evidence demonstrating overall profiteering; enquiries of 56 recipients showed 50 received ITC-related benefit, one was unregistered, and five were unreachable due to closure/liquidation/death. Consequently the DGAP's concluded profiteering amount was not accepted, no liability was fastened on the Respondent, and the complaint was thereby disposed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
