The High Court ruled that GST authorities must mandatorily apply Circular No. 183/15/2022-GST before disallowing ITC due to return mismatches. Mechanical reversal based solely on discrepancy was held unsustainable.
The High Court ruled that GST adjudication orders must contain detailed facts and reasons. Summary notices and orders lacking particulars were set aside as legally unsustainable.
The High Court ruled that buyers are not legally required to reverse ITC merely due to seller-issued discount credit notes. Rectification of GST returns was allowed where tax paid exceeded proposed reversal and no revenue loss occurred.
The proposed Section 147A retrospectively defines the “Assessing Officer” for Sections 148 and 148A, aiming to resolve High Court conflicts over faceless vs jurisdictional authority.
The Tribunal held that statutory jurisdiction must be strictly followed in income-tax proceedings. In absence of proof of transfer to the assessing ward, the assessment was declared invalid and set aside.
The Tribunal held that failure to provide opportunity to cross-examine foreign information sources amounted to violation of natural justice. Additions based on unverified documents were therefore invalid.
The Court set aside bail after finding concealment of criminal history and ignored evidence of forged qualifications. It laid down a recommendatory framework mandating full disclosure in bail applications.
The Tribunal held that interest income arising from working capital used in regular activities retains its character as business income. Section 80P relief cannot be denied merely because income arises as bank interest.
ITAT upheld revision under Section 263 after finding that the AO failed to verify the taxability of ₹669 crore received by a trust under Section 56(2)(x), rendering the assessment erroneous and prejudicial.
The Tribunal held that amounts reflected in regular books and disclosed in returns before search cannot be treated as unexplained expenditure. Section 69C was found inapplicable as no out-of-books spending was established.
