Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
A GST assessment confirming tax was set aside only to the extent of defect No. 1, because the assessee had not filed a proper reply with supporting documents to substantiate its exemption claim. The High Court noted that the adjudicating authority was not at fault for acting within the statutory timeline under Section 73, but balanced the interests of both sides by ordering de novo adjudication limited to that defect. The assessee was required to deposit 5% of the disputed tax and file the requisite documents, after which a fresh order on merits would be passed and any bank attachment would stand vacated on compliance.
A GST assessment confirming tax was set aside only to the extent of defect No. 1, because the assessee had not filed a proper reply with supporting documents to substantiate its exemption claim. The High Court noted that the adjudicating authority was not at fault for acting within the statutory timeline under Section 73, but balanced the interests of both sides by ordering de novo adjudication limited to that defect. The assessee was required to deposit 5% of the disputed tax and file the requisite documents, after which a fresh order on merits would be passed and any bank attachment would stand vacated on compliance.
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