The Court held that a 21-month delay in recording the satisfaction note violates the requirement of immediacy. It ruled that such delay renders proceedings time-barred and invalid.
The Court found that the appellate authority rejected the appeal solely on delay without examining the reasons provided. It held that such non-consideration renders the order unsustainable and directed fresh adjudication.
The Court emphasized the need for fair opportunity before finalizing tax demands. The petitioner was allowed to respond to the show-cause notice in fresh proceedings.
The issue involved denial of refund on the ground that services were intermediary in nature. The Court held that absence of findings on the agreement and nature of services invalidated the order. The matter was remanded for fresh adjudication with proper analysis.
The issue involved whether fresh scrutiny could be initiated after filing a modified return under Section 170A. The Court held that where assessment is already completed, the AO can only modify income to give effect to reorganisation.
Kerala High Court set aside ITAT orders as mechanical and non-speaking, holding that the Tribunal failed to independently analyze facts, consider submissions, and provide reasoned findings; matter remanded for fresh adjudication.
The Court set aside the Tribunals order as it relied on a precedent later reversed by the Supreme Court. The matter was remanded for fresh determination based on correct legal principles.
The Allahabad High Court allowed appeal filing before the GST Tribunal after its constitution. It held that appeals filed by June 30, 2026, must be accepted without limitation objections.
The judgment clarifies that subsequent departmental communications do not extend limitation periods. The appeal must be filed against the original order within statutory timelines.
The issue was rejection of a GST appeal for non-payment of pre-deposit. The Court held that the appellant must be given an opportunity to deposit and have the appeal decided on merits.
