Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Challenge concerns taxability of ocean freight under the IGST reverse charge mechanism and rejection of a rectification application. The court found the Proper Officer erred in treating a Supreme Court decision as prospective where constitutional precedent requires judgments to operate retrospectively unless expressly prospective, and concluded the SC ruling that Notification 10/2017 is clarificatory (not altering the taxable person under reverse charge) governs earlier import transactions; therefore the impugned confirmation of IGST demand and the March 25, 2025 rejection of rectification could not be sustained and the rectification application was allowed.
Challenge concerns taxability of ocean freight under the IGST reverse charge mechanism and rejection of a rectification application. The court found the Proper Officer erred in treating a Supreme Court decision as prospective where constitutional precedent requires judgments to operate retrospectively unless expressly prospective, and concluded the SC ruling that Notification 10/2017 is clarificatory (not altering the taxable person under reverse charge) governs earlier import transactions; therefore the impugned confirmation of IGST demand and the March 25, 2025 rejection of rectification could not be sustained and the rectification application was allowed.
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