Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
The Tribunal held that the statutory one-month timeline under section 148A(d) remains mandatory and is not extended by the broader surviving-period principle under section 148; the orders for AYs 2013-14 and 2014-15 were therefore time-barred and the consequential reassessment notices and orders were quashed. It further held that where action was founded solely on third-party search material, sections 153A/153C constituted the special route and general reassessment or assessment provisions could not be invoked without the required satisfaction note; the proceedings for AYs 2013-14, 2014-15 and 2020-21 were quashed on that ground. On merits, additions for accommodation entries, bank credits and duplicate loan credits were deleted because the sales and receipts were supported by records, bank statements are not books of account, and no objective inquiry or cash trail was shown.
The Tribunal held that the statutory one-month timeline under section 148A(d) remains mandatory and is not extended by the broader surviving-period principle under section 148; the orders for AYs 2013-14 and 2014-15 were therefore time-barred and the consequential reassessment notices and orders were quashed. It further held that where action was founded solely on third-party search material, sections 153A/153C constituted the special route and general reassessment or assessment provisions could not be invoked without the required satisfaction note; the proceedings for AYs 2013-14, 2014-15 and 2020-21 were quashed on that ground. On merits, additions for accommodation entries, bank credits and duplicate loan credits were deleted because the sales and receipts were supported by records, bank statements are not books of account, and no objective inquiry or cash trail was shown.
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