Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
The challenge concerned entitlement to input tax credit (ITC) affected by the limitation regime: the claim was found barred under the limitation provision of the CGST Act but fell within the period preserved by the proviso permitting claims within an alternate prescribed period, resulting in quashing of the impugned order insofar as it denied ITC on limitation grounds. Consequentially, departmental action premised solely on limitation was restrained, petitioners were granted liberty to seek refund which the department must decide on merits, and any bank accounts frozen under the impugned order were directed to be de-frozen.
The challenge concerned entitlement to input tax credit (ITC) affected by the limitation regime: the claim was found barred under the limitation provision of the CGST Act but fell within the period preserved by the proviso permitting claims within an alternate prescribed period, resulting in quashing of the impugned order insofar as it denied ITC on limitation grounds. Consequentially, departmental action premised solely on limitation was restrained, petitioners were granted liberty to seek refund which the department must decide on merits, and any bank accounts frozen under the impugned order were directed to be de-frozen.
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