Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
The HC dismissed the writ petition challenging imposition of penalty under s.122 CGST, finding fraudulent availment of input tax credit through creation and operation of non-existent bogus firms by the petitioner and associates. The court held that matters involving complex transactions and voluminous evidence arising from investigatory findings are ordinarily unsuitable for writ relief and are more appropriately addressed through statutory appellate remedies; the impugned order is appealable under s.107 CGST. The HC further upheld the validity of Circular No.254/11/2025 appointing the proper officer, observing the Additional Commissioner was empowered to issue the show cause notice under s.122. Writ relief was refused and the petition dismissed.
The HC dismissed the writ petition challenging imposition of penalty under s.122 CGST, finding fraudulent availment of input tax credit through creation and operation of non-existent bogus firms by the petitioner and associates. The court held that matters involving complex transactions and voluminous evidence arising from investigatory findings are ordinarily unsuitable for writ relief and are more appropriately addressed through statutory appellate remedies; the impugned order is appealable under s.107 CGST. The HC further upheld the validity of Circular No.254/11/2025 appointing the proper officer, observing the Additional Commissioner was empowered to issue the show cause notice under s.122. Writ relief was refused and the petition dismissed.
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TaxTMI 
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