Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Cross-segment derivatives manipulation: integrated order patterns can support interim restraints, while director liability requires responsibility, co...
GST interest on self-assessed return liabilities is discharged only when the Electronic Cash Ledger is debited towards the identified liability; a sufficient unappropriated cash balance does not stop interest until belated GSTR-3B filing. The later Rule 88B(1) proviso excluding amounts credited by the due date and continuously retained in that ledger operates prospectively, not for earlier periods. Notice proceedings remain valid where the taxpayer received the demand basis and computation, gave detailed replies, and established no actual prejudice. Denial of a requested personal hearing breached section 75(4), but did not require remand where the record was complete, the remaining issue was legal, and no lost substantive opportunity was identified. Interest demands were sustained, subject to reconciliation to prevent double recovery; substantive refund claims failed.
GST interest on self-assessed return liabilities is discharged only when the Electronic Cash Ledger is debited towards the identified liability; a sufficient unappropriated cash balance does not stop interest until belated GSTR-3B filing. The later Rule 88B(1) proviso excluding amounts credited by the due date and continuously retained in that ledger operates prospectively, not for earlier periods. Notice proceedings remain valid where the taxpayer received the demand basis and computation, gave detailed replies, and established no actual prejudice. Denial of a requested personal hearing breached section 75(4), but did not require remand where the record was complete, the remaining issue was legal, and no lost substantive opportunity was identified. Interest demands were sustained, subject to reconciliation to prevent double recovery; substantive refund claims failed.
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