The Court held that statutory amendments extending the ITC time limit override earlier restrictions. It ruled that ITC for FY 2018-19 can be validly claimed up to November 30, 2021. The demand based on earlier limitation was therefore unsustainable.
ITAT confirmed validity of reassessment based on cash deposit information. However, it reduced addition by applying peak credit theory due to withdrawal patterns
ITAT held that failure to record how seized material impacts taxable income invalidates proceedings. All assessments were quashed due to defective satisfaction note.
The Tribunal held that exemption benefits cannot be claimed under a notification issued after the filing of Bills of Entry. It ruled that the relevant date for duty determination is the date of filing, not clearance.
The case examined whether goods were actually supplied against invoices. The Tribunal ruled that lack of infrastructure and transport evidence indicated non-genuine transactions, justifying penalty.
The Court quashed the Section 148A(d) order for not aligning with binding Supreme Court decisions. It directed fresh adjudication following the principles laid down in earlier rulings.
The Tribunal held that shared advertising expenses do not constitute sponsorship service. It ruled that absence of a service provider–recipient relationship negates tax liability.
The Tribunal held that demand based on disclosed records cannot invoke extended limitation. It ruled that absence of fraud or suppression renders such demand time-barred.
The Tribunal held that the certificate issued by an authorized institution was valid. It ruled that absence of contrary evidence makes penalty unsustainable.
The Tribunal held that expansion of an existing manufacturing unit cannot be treated as setting up a new factory. Credit was allowed as the services were directly linked to manufacturing and not covered under exclusion clauses.
