Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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Where an efficacious statutory appeal exists under the GST framework, recourse to the appeal remedy must ordinarily precede invocation of Article 226. Applying the rule of exhaustion of statutory remedies as one of policy, convenience and discretion, the High Court found no special circumstance to depart from that principle and declined to examine the GST demand on merits. As the petitioner was still within the appeal period under Section 107, liberty was granted to file the appeal within seven days, and it was directed to be treated as within limitation subject to compliance with statutory requirements.
Where an efficacious statutory appeal exists under the GST framework, recourse to the appeal remedy must ordinarily precede invocation of Article 226. Applying the rule of exhaustion of statutory remedies as one of policy, convenience and discretion, the High Court found no special circumstance to depart from that principle and declined to examine the GST demand on merits. As the petitioner was still within the appeal period under Section 107, liberty was granted to file the appeal within seven days, and it was directed to be treated as within limitation subject to compliance with statutory requirements.
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