Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
The HC quashed consolidated show-cause notices issued by Respondent No.2 that clubbed multiple financial years for demand of GST and reversal of alleged ineligible ITC, holding such consolidation to be without jurisdiction and a judicial overreach. The court reaffirmed the statutory limitation scheme under the CGST Act, 2017 - tax periods are tied to returns (monthly or annual) and demands must respect the time limits in Sections 73 and 74 - so SCNs must be framed with reference to discrete financial years. Prior observations by a coordinate bench were noted but the HC granted the petition and set aside the impugned consolidated notices.
The HC quashed consolidated show-cause notices issued by Respondent No.2 that clubbed multiple financial years for demand of GST and reversal of alleged ineligible ITC, holding such consolidation to be without jurisdiction and a judicial overreach. The court reaffirmed the statutory limitation scheme under the CGST Act, 2017 - tax periods are tied to returns (monthly or annual) and demands must respect the time limits in Sections 73 and 74 - so SCNs must be framed with reference to discrete financial years. Prior observations by a coordinate bench were noted but the HC granted the petition and set aside the impugned consolidated notices.
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