ITAT Delhi deleted a Rs. 50 lakh addition under Section 68 after finding that the investor company had directly responded to notices and furnished supporting documents. The Tribunal held that the identity, genuineness, and source of investment were adequately proved.
The Calcutta High Court held that proceedings based on Rule 96(10) of the CGST Rules could not continue after the provision was omitted without any saving clause. The Court quashed the GST refund demand order passed after deletion of the rule.
The Tribunal restored issues relating to comparable company margins and working capital adjustment after finding that the assessee’s submissions required verification. The appeal was allowed for statistical purposes.
NCLAT observed that royalty payment obligation flowed directly from Technical Guidance Agreement and did not depend on issuance of invoices. Debt and default were therefore held established.
ITAT Delhi upheld addition of Rs. 2.78 crore after finding that the assessee had voluntarily admitted undisclosed stock during survey and post-survey proceedings. The Tribunal held that later retraction without supporting evidence could not displace signed statements and inventory records.
The Court ruled that tax authorities could not rely on COVID-related extension of limitation granted by the Supreme Court to justify delayed revision proceedings. The impugned GST revision order was therefore declared time-barred.
The Supreme Court ruled that limitation under Section 263 must be calculated from the original assessment order where the issue revised was not part of reassessment proceedings. The Court held that reassessment does not reopen the entire assessment for all purposes.
The Supreme Court ruled that limitation for revisional proceedings under Section 263 must be counted from the original assessment order where the issues are unrelated to reassessment proceedings. The Court dismissed the Revenue’s appeal as the revision order was held time-barred.
ITAT Hyderabad held that the reassessment notice issued for AY 2015-16 after 31.03.2022 was barred by limitation under the first proviso to Section 149 and therefore invalid.
The Karnataka High Court condoned a 60-day delay in filing a GST appeal and restored the matter for decision on merits. The Court relied on earlier decisions passed in similar circumstances.
