Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
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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