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...
Entitlement to refund of unutilised input tax credit on corporate amalgamation is governed by the transfer mechanism under Section 87 and statutory compliance with FORM GST ITC-02; the transferee may receive unutilised ITC only if transfer formalities, including valid registration of the transferor at time of transfer and settlement of liabilities, are observed, and registration cancellation takes effect from the date of the sanctioning order. Partial transfer of ITC without complete compliance and concurrent irregular registration actions by officers vitiate relief and invoke the doctrine of pari delicto, preventing either party from obtaining refund where both are at fault. Directions issued for strict procedural adherence in future amalgamations.
Entitlement to refund of unutilised input tax credit on corporate amalgamation is governed by the transfer mechanism under Section 87 and statutory compliance with FORM GST ITC-02; the transferee may receive unutilised ITC only if transfer formalities, including valid registration of the transferor at time of transfer and settlement of liabilities, are observed, and registration cancellation takes effect from the date of the sanctioning order. Partial transfer of ITC without complete compliance and concurrent irregular registration actions by officers vitiate relief and invoke the doctrine of pari delicto, preventing either party from obtaining refund where both are at fault. Directions issued for strict procedural adherence in future amalgamations.
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