Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
The HC held that reassessment proceedings for Assessment Year 2015-16 were governed by the amended limitation regime under section 149 effective from 01.09.2024. A notice issued under section 148 beyond three years from the end of the relevant assessment year was without jurisdiction unless the conditions in section 149(1)(b) were satisfied. As no material showed that escaped income met the statutory threshold for invoking the extended period, the jurisdictional basis for reassessment failed. The show-cause notice under section 148A(b), the order under section 148A(d), and the notice under section 148 were quashed.
The HC held that reassessment proceedings for Assessment Year 2015-16 were governed by the amended limitation regime under section 149 effective from 01.09.2024. A notice issued under section 148 beyond three years from the end of the relevant assessment year was without jurisdiction unless the conditions in section 149(1)(b) were satisfied. As no material showed that escaped income met the statutory threshold for invoking the extended period, the jurisdictional basis for reassessment failed. The show-cause notice under section 148A(b), the order under section 148A(d), and the notice under section 148 were quashed.
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