Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Time sought by an assessee through adjournments in proceedings under section 148A(b), including extended time, must be excluded while computing limitation under the fifth and sixth provisos to section 149. Where no reply is ultimately filed and a further adjournment request is rejected, the rejection date is treated as the deemed date of reply. On that basis, the Assessing Officer had the statutory period available thereafter, so the order under section 148A(d) and the consequential notice under section 148 issued on the next day were within limitation. The limitation challenge was rejected and the reassessment proceedings were sustained.
Time sought by an assessee through adjournments in proceedings under section 148A(b), including extended time, must be excluded while computing limitation under the fifth and sixth provisos to section 149. Where no reply is ultimately filed and a further adjournment request is rejected, the rejection date is treated as the deemed date of reply. On that basis, the Assessing Officer had the statutory period available thereafter, so the order under section 148A(d) and the consequential notice under section 148 issued on the next day were within limitation. The limitation challenge was rejected and the reassessment proceedings were sustained.
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