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...
AT held that the DGAP investigation established that the Respondent did not avail any impermissible benefit of input tax credit in respect of post-GST real estate transactions and therefore did not contravene section 171(1) of the CGST Act, 2017. The Tribunal accepted the DGAP report dated 23.05.2025 and concluded there is no liability for anti-profiteering measures against the Respondent. Accordingly, the AT dismissed the allegation of contravention, recorded that no refund, penalty or adjustment under the anti-profiteering regime is warranted, and directed that the DGAP report be given effect as the operative finding in the proceedings.
AT held that the DGAP investigation established that the Respondent did not avail any impermissible benefit of input tax credit in respect of post-GST real estate transactions and therefore did not contravene section 171(1) of the CGST Act, 2017. The Tribunal accepted the DGAP report dated 23.05.2025 and concluded there is no liability for anti-profiteering measures against the Respondent. Accordingly, the AT dismissed the allegation of contravention, recorded that no refund, penalty or adjustment under the anti-profiteering regime is warranted, and directed that the DGAP report be given effect as the operative finding in the proceedings.
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TaxTMI 
TaxTMI 
of 4918 
