Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Provisional attachment under Section 83 of the CGST/KGST Act was challenged as time-barred. The court held that Section 83 expressly limits the attachment's operation to one year, and on expiry the attachment and all consequential proceedings and notices cease to have effect; accordingly, the impugned attachment was declared non-subsisting due to lapse of the statutory period. Relying on binding precedent, it further held that after expiry of the one-year period, the Revenue is precluded from re-invoking Section 83 to issue a fresh or new provisional attachment in respect of the same matter. Petition was disposed with directions. - HC
Provisional attachment under Section 83 of the CGST/KGST Act was challenged as time-barred. The court held that Section 83 expressly limits the attachment's operation to one year, and on expiry the attachment and all consequential proceedings and notices cease to have effect; accordingly, the impugned attachment was declared non-subsisting due to lapse of the statutory period. Relying on binding precedent, it further held that after expiry of the one-year period, the Revenue is precluded from re-invoking Section 83 to issue a fresh or new provisional attachment in respect of the same matter. Petition was disposed with directions. - HC
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