Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Section 74(1) may be invoked for delayed GST payment only where the show cause notice discloses foundational facts permitting an inference of fraud, wilful misstatement, or suppression with intent to evade tax. Mere mechanical reproduction of those statutory expressions does not satisfy that condition. Because the notice contained no such factual basis, recourse to section 74(1) was unwarranted; the Tribunal sustained the setting aside of the proceedings and dismissed the Revenue's appeal.
Section 74(1) may be invoked for delayed GST payment only where the show cause notice discloses foundational facts permitting an inference of fraud, wilful misstatement, or suppression with intent to evade tax. Mere mechanical reproduction of those statutory expressions does not satisfy that condition. Because the notice contained no such factual basis, recourse to section 74(1) was unwarranted; the Tribunal sustained the setting aside of the proceedings and dismissed the Revenue's appeal.
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TaxTMI 
TaxTMI 
of 4910 
