Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
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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