TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
A single show-cause notice or composite assessment order cannot cover more than one tax period under Sections 73 and 74 of the GST Act, 2017. Following its earlier Division Bench view, the HC held that separate proceedings are required for each assessment year once the annual return due date has passed. As the impugned order covered multiple financial years in one proceeding, it was set aside. The Court did not examine the other grounds and left them open. Fresh proceedings may be initiated separately for each assessment year, with exclusion of the intervening period for limitation.
A single show-cause notice or composite assessment order cannot cover more than one tax period under Sections 73 and 74 of the GST Act, 2017. Following its earlier Division Bench view, the HC held that separate proceedings are required for each assessment year once the annual return due date has passed. As the impugned order covered multiple financial years in one proceeding, it was set aside. The Court did not examine the other grounds and left them open. Fresh proceedings may be initiated separately for each assessment year, with exclusion of the intervening period for limitation.
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