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 allowed the writ petitions and quashed and set aside the impugned show-cause notices issued to the petitioners dated 13.02.2025 and 23.05.2025. The court held the notices under Rule 4(2) read with s.31 of the GVAT Act lacked any communicated opinion or tangible material evidencing turnover escaping assessment, amounting to impermissible reopening and review in the absence of cogent grounds; further the reassessment demands were time-barred under the statutory eight-year limitation. Separately, provisions conferring unfettered discretion (notably s.6 and the exemption in s.22) were declared constitutionally invalid for constituting uncanalised, arbitrary delegation of taxing power without guiding principles or safeguards.
The HC allowed the writ petitions and quashed and set aside the impugned show-cause notices issued to the petitioners dated 13.02.2025 and 23.05.2025. The court held the notices under Rule 4(2) read with s.31 of the GVAT Act lacked any communicated opinion or tangible material evidencing turnover escaping assessment, amounting to impermissible reopening and review in the absence of cogent grounds; further the reassessment demands were time-barred under the statutory eight-year limitation. Separately, provisions conferring unfettered discretion (notably s.6 and the exemption in s.22) were declared constitutionally invalid for constituting uncanalised, arbitrary delegation of taxing power without guiding principles or safeguards.
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