Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Appointment of Registrars as adjudicating officers under Companies Act reallocates territorial jurisdiction and sets appeal route to Regional Director...
Composite supply of drilling services and site specific chemicals characterised as composite supply; prior advance rulings set aside, tax rate left op...
Cross country pipeline classification and ITC entitlement: pipelines outside factory treated as immovable, ITC disallowed under Section 17 restriction...
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The article addresses consolidation of assessment periods under the GST statutory scheme, holding that tax liability and limitation run year by year tied to returns and that separate limitation timelines apply to each financial year; therefore issuing a single show cause notice aggregating multiple years is impermissible and was quashed. It explains that allegations of fraudulent availment do not create a rule permitting clubbing of distinct tax periods, although fraud affects limitation for the relevant year. The revenue may reissue year wise notices conforming to the statutory periodicity and may revive challenges if controlling precedent is altered by higher courts.
The article addresses consolidation of assessment periods under the GST statutory scheme, holding that tax liability and limitation run year by year tied to returns and that separate limitation timelines apply to each financial year; therefore issuing a single show cause notice aggregating multiple years is impermissible and was quashed. It explains that allegations of fraudulent availment do not create a rule permitting clubbing of distinct tax periods, although fraud affects limitation for the relevant year. The revenue may reissue year wise notices conforming to the statutory periodicity and may revive challenges if controlling precedent is altered by higher courts.
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