Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
HC held that continued blocking of petitioner's ITC in the Electronic Credit Ledger beyond one year under Rule 86A of the 2017 Rules is ultra vires and unsustainable. Relying on the SC's interpretation of provisional attachment as a protective, pre-emptive measure and not a mode of recovery, the HC held that the statutory one-year period is sufficient for investigation and cannot be indirectly extended absent fresh material or changed circumstances. As no further proceedings or new grounds were shown by the revenue, the renewed blocking of ITC after 21.11.2024 was quashed. The impugned action was set aside and the writ petition allowed.
HC held that continued blocking of petitioner's ITC in the Electronic Credit Ledger beyond one year under Rule 86A of the 2017 Rules is ultra vires and unsustainable. Relying on the SC's interpretation of provisional attachment as a protective, pre-emptive measure and not a mode of recovery, the HC held that the statutory one-year period is sufficient for investigation and cannot be indirectly extended absent fresh material or changed circumstances. As no further proceedings or new grounds were shown by the revenue, the renewed blocking of ITC after 21.11.2024 was quashed. The impugned action was set aside and the writ petition allowed.
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