Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
The note examines sustainability of composite notices issued under the CGST/SGST scheme for multiple assessment years, holding that the concept of a "valid return" and the limitation linked to the financial year constrain multi year adjudication. It recognises that officers may investigate instances spanning years but stresses that consolidated adjudication can prejudice the taxpayer; therefore impugned multi year notices were quashed with liberty to issue fresh, year wise notices and with the pendency period excluded from limitation while other contentions remain open.
The note examines sustainability of composite notices issued under the CGST/SGST scheme for multiple assessment years, holding that the concept of a "valid return" and the limitation linked to the financial year constrain multi year adjudication. It recognises that officers may investigate instances spanning years but stresses that consolidated adjudication can prejudice the taxpayer; therefore impugned multi year notices were quashed with liberty to issue fresh, year wise notices and with the pendency period excluded from limitation while other contentions remain open.
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