Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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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