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 directed the Respondent Department to re-credit the Petitioner's Input Tax Credit (ITC) of Rs. 23,32,278/- to the Petitioner's Electronic Credit Ledger within four weeks, permitting manual intervention if necessary, upon finding no dispute as to entitlement and that non-credit arose solely from a technical limitation of the GST portal preventing issuance of PMT-03. The court held that the refund cannot be withheld on account of the technical impediment and ordered immediate compliance with the re-crediting directive. The petition is disposed of accordingly.
The HC directed the Respondent Department to re-credit the Petitioner's Input Tax Credit (ITC) of Rs. 23,32,278/- to the Petitioner's Electronic Credit Ledger within four weeks, permitting manual intervention if necessary, upon finding no dispute as to entitlement and that non-credit arose solely from a technical limitation of the GST portal preventing issuance of PMT-03. The court held that the refund cannot be withheld on account of the technical impediment and ordered immediate compliance with the re-crediting directive. The petition is disposed of accordingly.
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