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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Parallel proceedings under the CGST/UPGST Acts for the same goods and cause of action are impermissible where transit-release proceedings have already resulted in recovery of tax and penalty; the first appellate reduction of duplicated liability was therefore sustained. Goods in transit must carry a tax invoice and a valid e-way bill generated before movement begins. Manual invoices furnished more than three months after interception, without upload on the GST portal, lacked evidentiary credibility and could not retrospectively validate the movement or cure missing mandatory documentation. The taxpayer's appeal failed, while the partial liability reduction for duplicated proceedings remained intact.
Parallel proceedings under the CGST/UPGST Acts for the same goods and cause of action are impermissible where transit-release proceedings have already resulted in recovery of tax and penalty; the first appellate reduction of duplicated liability was therefore sustained. Goods in transit must carry a tax invoice and a valid e-way bill generated before movement begins. Manual invoices furnished more than three months after interception, without upload on the GST portal, lacked evidentiary credibility and could not retrospectively validate the movement or cure missing mandatory documentation. The taxpayer's appeal failed, while the partial liability reduction for duplicated proceedings remained intact.
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