Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
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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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