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    GST appeal limitation cannot be extended beyond the statutory condonable period; Section 5 of the Limitation Act is excluded.
    GST penalty cannot exceed the statutory maximum under Section 125 when split between CGST and SGST.
    Procedural time limit cannot defeat retrospective input tax credit relief; rectification application restored for fresh merits review.
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      Mechanical approval for reassessment sanction under section 151,...

      Mechanical sanction for reassessment invalidates jurisdiction where approval under section 151 is recorded only as "Yes".

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      Income TaxMay 18, 2026Case LawsAT
      Mechanical approval for reassessment sanction under section 151, recorded only as "Yes", was held to show no proper application of mind and no statutory due satisfaction. Relying on the coordinate Bench view in Sandhya Sharma, the Tribunal found that such a perfunctory sanction vitiated the assumption of jurisdiction under sections 147/148. The reassessment initiation was therefore bad in law, and the assessment order was quashed on the jurisdictional ground.

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      ActsIncome Tax