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...
Vague show-cause notices alleging ineligible input tax credit without identifying invoices, the nature of ineligibility, or the basis for rejection cannot support denial of an inverted-duty refund. Invoice details supplied by the taxpayer do not cure that defect, and an appellate authority cannot introduce a distinct ground not stated in the notice, as doing so breaches natural justice. Eligibility of unutilised input tax credit must be determined through proceedings for wrongful availment or utilisation before the credit can be disallowed. Refund proceedings cannot be used collaterally to decide credit eligibility; absent a prior determination, refund denial on that basis is unsustainable.
Vague show-cause notices alleging ineligible input tax credit without identifying invoices, the nature of ineligibility, or the basis for rejection cannot support denial of an inverted-duty refund. Invoice details supplied by the taxpayer do not cure that defect, and an appellate authority cannot introduce a distinct ground not stated in the notice, as doing so breaches natural justice. Eligibility of unutilised input tax credit must be determined through proceedings for wrongful availment or utilisation before the credit can be disallowed. Refund proceedings cannot be used collaterally to decide credit eligibility; absent a prior determination, refund denial on that basis is unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
