Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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