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...
GST assessment orders issued under s.74 were challenged on the ground that tax liability was fastened solely on turnover reflected in the income-tax portal, allegedly based on an inflated return, despite a marked mismatch between bank receipts and reported turnover. The Court held that, given the significant discrepancies, the taxpayer's records required forensic examination to ascertain actual turnover and whether liability could be determined merely from the income-tax declaration. Since the impugned orders had also superseded earlier assessments, the matters were remitted to the department to conduct the examination and pass fresh orders on merits subject to stipulated conditions, and the petitions were disposed accordingly. - HC
GST assessment orders issued under s.74 were challenged on the ground that tax liability was fastened solely on turnover reflected in the income-tax portal, allegedly based on an inflated return, despite a marked mismatch between bank receipts and reported turnover. The Court held that, given the significant discrepancies, the taxpayer's records required forensic examination to ascertain actual turnover and whether liability could be determined merely from the income-tax declaration. Since the impugned orders had also superseded earlier assessments, the matters were remitted to the department to conduct the examination and pass fresh orders on merits subject to stipulated conditions, and the petitions were disposed accordingly. - HC
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