Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
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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