Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
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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