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 petition and granted retrospective relief: the O-in-O dated 29 Dec 2023 and the O-in-A dated 11 Jul 2024 are set aside insofar as they denied the petitioner the benefit of Circular No. 228/22/2024-GST dated 15 Jul 2024. The court held that, although those orders were rendered before issuance of the circular, the petitioner cannot be deprived of its benefit for the levy of GST on reinsurance of specified general and life insurance schemes for the period 01 Jul 2017 to 24 Jan 2018. The circular is declared squarely applicable to the petitioner and the decision in AXA France Vie-India is held to be applicable. Petition disposed.
The HC allowed the petition and granted retrospective relief: the O-in-O dated 29 Dec 2023 and the O-in-A dated 11 Jul 2024 are set aside insofar as they denied the petitioner the benefit of Circular No. 228/22/2024-GST dated 15 Jul 2024. The court held that, although those orders were rendered before issuance of the circular, the petitioner cannot be deprived of its benefit for the levy of GST on reinsurance of specified general and life insurance schemes for the period 01 Jul 2017 to 24 Jan 2018. The circular is declared squarely applicable to the petitioner and the decision in AXA France Vie-India is held to be applicable. Petition disposed.
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