Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Consolidation of separate tax periods into a single show cause notice under the CGST Act is impermissible: the statutory scheme ties tax liability and assessment to returns for each tax period and the limitation for demand and recovery runs year by year, so aggregating financial years collapses the legislated period-wise structure and prejudices the assessee; accordingly a consolidated notice and order covering multiple financial years were quashed. Allegations of fraudulent availment of input tax credit may extend the limitation window but do not authorize clubbing distinct tax periods into one proceeding; fresh notices may be issued year-wise in accordance with the statute.
Consolidation of separate tax periods into a single show cause notice under the CGST Act is impermissible: the statutory scheme ties tax liability and assessment to returns for each tax period and the limitation for demand and recovery runs year by year, so aggregating financial years collapses the legislated period-wise structure and prejudices the assessee; accordingly a consolidated notice and order covering multiple financial years were quashed. Allegations of fraudulent availment of input tax credit may extend the limitation window but do not authorize clubbing distinct tax periods into one proceeding; fresh notices may be issued year-wise in accordance with the statute.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
