Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
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...
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Section 129(3) of the CGST Act imposes separate mandatory deadlines: the penalty notice must be issued within seven days of detention or seizure, and the penalty order must follow within seven days after service of that notice. The latter period runs from service, not from a reply, valuation exercise or other intervening event. Because detention and seizure are coercive restraints on goods and conveyances, administrative difficulty, minimal delay and inspection-stage timelines cannot extend either deadline; a delayed Section 129 order is invalid. The affected person must receive an opportunity of hearing. Invalidity of Section 129 proceedings does not preclude separately lawful action under other GST provisions.
Section 129(3) of the CGST Act imposes separate mandatory deadlines: the penalty notice must be issued within seven days of detention or seizure, and the penalty order must follow within seven days after service of that notice. The latter period runs from service, not from a reply, valuation exercise or other intervening event. Because detention and seizure are coercive restraints on goods and conveyances, administrative difficulty, minimal delay and inspection-stage timelines cannot extend either deadline; a delayed Section 129 order is invalid. The affected person must receive an opportunity of hearing. Invalidity of Section 129 proceedings does not preclude separately lawful action under other GST provisions.
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