Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
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Clubbing multiple tax periods/financial years in a single composite show-cause notice under s.73/s.74 of the CGST/KGST Act was held impermissible because the statutory scheme treats each financial year as an independent assessment unit with separate returns, reconciliation, evaluation of transactions/ITC, and year-specific limitation; the Act does not contemplate consolidated proceedings, rendering such notices without jurisdiction. Consequently, the composite show-cause notice covering FY 2019-20 to 2023-24 and all consequential proceedings were quashed, with liberty reserved to initiate fresh action in accordance with law. - HC
Clubbing multiple tax periods/financial years in a single composite show-cause notice under s.73/s.74 of the CGST/KGST Act was held impermissible because the statutory scheme treats each financial year as an independent assessment unit with separate returns, reconciliation, evaluation of transactions/ITC, and year-specific limitation; the Act does not contemplate consolidated proceedings, rendering such notices without jurisdiction. Consequently, the composite show-cause notice covering FY 2019-20 to 2023-24 and all consequential proceedings were quashed, with liberty reserved to initiate fresh action in accordance with law. - HC
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