The Tribunal held that when sales are not disputed, the entire value of alleged bogus purchases cannot be added under section 69C. Only the embedded profit element is taxable.
The assessment was quashed because the mandatory notice under section 143(2) was issued by an officer lacking jurisdiction. The ruling confirms that jurisdiction must exist at the notice stage itself.
The Tribunal ruled that AMP expenses incurred by a brand-owning trader cannot be allocated to contract manufacturers without proof of obligation or agreement. Tax incentives enjoyed by related entities alone were held insufficient.
The Tribunal held that reassessment initiated by a jurisdictional officer after the faceless scheme became mandatory was invalid. The key takeaway is that failure to follow the faceless mechanism nullifies the entire reopening, regardless of merits.
The Court ruled that a 67-day delay in filing GST appeal deserved condonation as the taxpayer was pursuing statutory remedies. The appellate authority was directed to hear the appeal on merits.
The High Court ruled that the appellate authority has power to condone delay under Section 107(4) of the GST Act. The key takeaway is that GST appeal timelines are not mandatory and require consideration on merits.
The Tribunal held that when sales are accepted and purchases are unverifiable, only the embedded profit can be taxed. Full disallowance of purchases was found unsustainable.
Emphasizing the gravity of cancellation, the Court intervened where illness prevented compliance. The key takeaway is that genuine hardship can warrant restoration of registration.
ITAT held that dismissing a ground without reasons violates appellate duty. The 43B disallowance was remanded for fresh, reasoned adjudication.
The Supreme Court upheld the quashing of a reassessment notice issued after four years. It ruled that reopening based on a change of opinion, without any suppression of facts, is invalid.
