Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The note addresses validity of a single show cause notice aggregating multiple financial years under the CGST Act: each financial year is a distinct tax period with separate limitation periods under Sections 73(10) and 74(10), so limitation runs year by year and notices must respect that structure; allegation of fraudulent availment of input tax credit permits only application of any extended limitation provided by law but does not authorise clubbing of different years into one notice. Consequence: a consolidated multi year notice is invalid to the extent of aggregation, but respondents may reissue year wise notices complying with the statutory limitation regime.
The note addresses validity of a single show cause notice aggregating multiple financial years under the CGST Act: each financial year is a distinct tax period with separate limitation periods under Sections 73(10) and 74(10), so limitation runs year by year and notices must respect that structure; allegation of fraudulent availment of input tax credit permits only application of any extended limitation provided by law but does not authorise clubbing of different years into one notice. Consequence: a consolidated multi year notice is invalid to the extent of aggregation, but respondents may reissue year wise notices complying with the statutory limitation regime.
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