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...
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Assessment under the Black Money Act starts only on service of notice under section 10, so no assessment proceedings exist in law before that date. On that basis, time excluded for foreign information exchange under Explanation 1 to section 11 can cover only the period overlapping with the running assessment period, not any earlier period before notice service. The Tribunal held that the Revenue wrongly excluded pre-notice time, and the assessment was completed after the last permissible date. The order was therefore time-barred, without jurisdiction and non est, and was quashed; the merits were left open and the departmental appeal became infructuous.
Assessment under the Black Money Act starts only on service of notice under section 10, so no assessment proceedings exist in law before that date. On that basis, time excluded for foreign information exchange under Explanation 1 to section 11 can cover only the period overlapping with the running assessment period, not any earlier period before notice service. The Tribunal held that the Revenue wrongly excluded pre-notice time, and the assessment was completed after the last permissible date. The order was therefore time-barred, without jurisdiction and non est, and was quashed; the merits were left open and the departmental appeal became infructuous.
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