Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Entitlement to concessional IGST at 0.1% under Notification No. 41/2017-I.T.(Rate) turns on strict compliance with the Notification's prescribed conditions, particularly that the registered recipient must place an order on the registered supplier and goods must move from the registered supplier either directly to the export point or to a registered warehouse as specified. The court held that the scheme contemplates only the registered supplier and registered recipient and that supply to a third party does not meet the conditions; purposive construction in favour of the taxpayer could not override clear, express conditions. Outcome: concession denied and writ dismissed.
Entitlement to concessional IGST at 0.1% under Notification No. 41/2017-I.T.(Rate) turns on strict compliance with the Notification's prescribed conditions, particularly that the registered recipient must place an order on the registered supplier and goods must move from the registered supplier either directly to the export point or to a registered warehouse as specified. The court held that the scheme contemplates only the registered supplier and registered recipient and that supply to a third party does not meet the conditions; purposive construction in favour of the taxpayer could not override clear, express conditions. Outcome: concession denied and writ dismissed.
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