Composite residential flat exemption upheld where supplementary agreement merged adjoining units and additional evidence supported the taxpayer's inve...
Urgent interim relief exception permits commercial suit without pre-institution mediation where immediate disclosure and asset protection are genuinel...
Portal order discrepancies invalidated rectification rejection, requiring fresh reasoned consideration after hearing and prompt communication of the o...
Reassessment after search was held time-barred for A.Y. 2013-14 because the ten-year limit under section 149 extended only up to A.Y. 2014-15. For A.Ys. 2014-15 to 2017-18, reopening beyond six years failed because the alleged escaped income was not represented as an asset, so jurisdiction was lacking. For A.Ys. 2018-19 to 2020-21, the notices were invalid since the income alleged did not satisfy the statutory conditions for reopening beyond three years under section 149(1)(b). The Tribunal also reduced the gross profit rate on unaccounted sales to 10% for A.Y. 2021-22, held the post-search assessment for A.Y. 2022-23 invalid for want of section 148/148B procedure, and deleted the section 41(1) addition for A.Y. 2023-24 as no cessation of liability was shown.
Reassessment after search was held time-barred for A.Y. 2013-14 because the ten-year limit under section 149 extended only up to A.Y. 2014-15. For A.Ys. 2014-15 to 2017-18, reopening beyond six years failed because the alleged escaped income was not represented as an asset, so jurisdiction was lacking. For A.Ys. 2018-19 to 2020-21, the notices were invalid since the income alleged did not satisfy the statutory conditions for reopening beyond three years under section 149(1)(b). The Tribunal also reduced the gross profit rate on unaccounted sales to 10% for A.Y. 2021-22, held the post-search assessment for A.Y. 2022-23 invalid for want of section 148/148B procedure, and deleted the section 41(1) addition for A.Y. 2023-24 as no cessation of liability was shown.
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