Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Personal hearing requirements in GST adjudication were satisfied by prior opportunities and written submissions; appellate limitation received writ-pe...
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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