Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Issuing a composite show-cause notice covering multiple tax periods under the CGST/KGST regime was treated as a jurisdictional defect, following the view that clubbing separate periods in one notice is illegal and impermissible. The impugned notice and the adjudication order founded on it were set aside. Liberty was reserved to the revenue to initiate fresh proceedings through separate show-cause notices for each tax period, and all other contentions were left open.
Issuing a composite show-cause notice covering multiple tax periods under the CGST/KGST regime was treated as a jurisdictional defect, following the view that clubbing separate periods in one notice is illegal and impermissible. The impugned notice and the adjudication order founded on it were set aside. Liberty was reserved to the revenue to initiate fresh proceedings through separate show-cause notices for each tax period, and all other contentions were left open.
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