Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Clubbing of tax periods in a single Section 74 show cause notice is impermissible because the CGST statutory scheme treats each financial year as a distinct tax period with separate limitation and procedural rights; aggregating years conflates distinct limitation dates and denies year wise rights, and allegations of fraudulent input tax credit do not authorise consolidation. Applying that principle, the court quashed the consolidated notice covering multiple financial years but permitted respondents liberty to reissue notices strictly year wise in accordance with the statutory scheme and to revive proceedings if higher forum decisions permit.
Clubbing of tax periods in a single Section 74 show cause notice is impermissible because the CGST statutory scheme treats each financial year as a distinct tax period with separate limitation and procedural rights; aggregating years conflates distinct limitation dates and denies year wise rights, and allegations of fraudulent input tax credit do not authorise consolidation. Applying that principle, the court quashed the consolidated notice covering multiple financial years but permitted respondents liberty to reissue notices strictly year wise in accordance with the statutory scheme and to revive proceedings if higher forum decisions permit.
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