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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Retrospective withdrawal of net SGST reimbursement under IPR 2015 was invalidated as arbitrary, discriminatory and unconstitutional insofar as it affected projects that had invested and commenced production in reliance on the scheme. A policy-review power permitted prospective modification but did not support retrospective deprivation without material showing overriding public interest. Failure to issue or communicate a timely rejection after inspection and verification triggered deemed approval of provisional Priority Sector status; that approval remained subject to reimbursement conditions and quantification. The Negative List did not exclude clinker-based cement manufacture where the specified exception, investment threshold and verification supported eligibility. Net SGST reimbursement must therefore be determined and released under IPR 2015, subject to applicable conditions.
Retrospective withdrawal of net SGST reimbursement under IPR 2015 was invalidated as arbitrary, discriminatory and unconstitutional insofar as it affected projects that had invested and commenced production in reliance on the scheme. A policy-review power permitted prospective modification but did not support retrospective deprivation without material showing overriding public interest. Failure to issue or communicate a timely rejection after inspection and verification triggered deemed approval of provisional Priority Sector status; that approval remained subject to reimbursement conditions and quantification. The Negative List did not exclude clinker-based cement manufacture where the specified exception, investment threshold and verification supported eligibility. Net SGST reimbursement must therefore be determined and released under IPR 2015, subject to applicable conditions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
