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...
Excess IGST paid on zero-rated cashew-kernel exports because of a clerical GSTR-3B classification error remains refundable where export turnover and tax were correctly declared in GSTR-1. Incorrect reporting in the domestic-supply column may block automated Customs processing, prompting a second correctly reported payment and refund of only that later payment. Reconciliation establishing the original payment as excess supports refund, as retaining tax paid twice lacks authority of law. Procedural difficulties in GST refund processing cannot justify withholding the unrecovered original IGST payment.
Excess IGST paid on zero-rated cashew-kernel exports because of a clerical GSTR-3B classification error remains refundable where export turnover and tax were correctly declared in GSTR-1. Incorrect reporting in the domestic-supply column may block automated Customs processing, prompting a second correctly reported payment and refund of only that later payment. Reconciliation establishing the original payment as excess supports refund, as retaining tax paid twice lacks authority of law. Procedural difficulties in GST refund processing cannot justify withholding the unrecovered original IGST payment.
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