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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Consolidation of multiple financial years/tax periods into a single show cause notice under Section 74 of the CGST Act was contested; the court preferred subsequent Bombay High Court decisions finding such consolidation impermissible, holding that authorities within the State are bound by those later judgments and that the Delhi High Court decision does not operate as a merger where the Supreme Court dismissed review in limine. The court permitted respondents to revive the petition if Bombay High Court decisions are set aside and expressly allowed reissuance of notice strictly in terms of Section 74 if no other legal impediment exists.
Consolidation of multiple financial years/tax periods into a single show cause notice under Section 74 of the CGST Act was contested; the court preferred subsequent Bombay High Court decisions finding such consolidation impermissible, holding that authorities within the State are bound by those later judgments and that the Delhi High Court decision does not operate as a merger where the Supreme Court dismissed review in limine. The court permitted respondents to revive the petition if Bombay High Court decisions are set aside and expressly allowed reissuance of notice strictly in terms of Section 74 if no other legal impediment exists.
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TaxTMI 
TaxTMI 
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