Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
Sections 73 and 74 of the CGST Act do not bar a common or consolidated show cause notice for more than one tax period or financial year. The Court held that the references to "any period" and the limitation provisions do not confine notice issuance to a single financial year, while each component of a consolidated notice must still independently satisfy the applicable limitation test. It also rejected the objection based on pecuniary jurisdiction of the proper officer. Where Orders-in-Original were challenged, the Court restored the statutory position and granted time to file appeals, with limitation objections not to be raised if appeals were filed within the period allowed.
Sections 73 and 74 of the CGST Act do not bar a common or consolidated show cause notice for more than one tax period or financial year. The Court held that the references to "any period" and the limitation provisions do not confine notice issuance to a single financial year, while each component of a consolidated notice must still independently satisfy the applicable limitation test. It also rejected the objection based on pecuniary jurisdiction of the proper officer. Where Orders-in-Original were challenged, the Court restored the statutory position and granted time to file appeals, with limitation objections not to be raised if appeals were filed within the period allowed.
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