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    Registered sale deed and banking evidence supported capital gains reinvestment claim; unexplained money additions were deleted.
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      Assessment proceedings under the GST enactments must be confined...

      Composite GST assessment for multiple years is impermissible; year-wise proceedings required and fresh action permitted with limitation exclusion.

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      GSTApril 16, 2026Case LawsHC
      Assessment proceedings under the GST enactments must be confined to the relevant tax period, and a single composite show cause notice or composite assessment order for multiple assessment years is impermissible. Following prior High Court authority, the court held that the impugned DRC-01 notice and assessment order, both framed on a combined basis, were unsustainable; separate issuance of DRC-07 did not cure the defect. The composite assessment order was set aside, and the respondents were given liberty to initiate fresh year-wise proceedings. The period from the impugned order until receipt of the court's order was directed to be excluded for limitation purposes.

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      ActsIncome Tax