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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A search assessment founded on a single consolidated satisfaction note covering multiple assessment years, without year-wise identification of material, was held to suffer from a fatal jurisdictional defect. The Tribunal held that the assessee could challenge the validity of the foundational assessment in appeal against the revision order, and that the original assessment was void in law because valid jurisdiction under the search assessment provisions had not been assumed for the year in question. As the foundational assessment was unsustainable, the revisionary order under section 263 could not survive and was set aside.
A search assessment founded on a single consolidated satisfaction note covering multiple assessment years, without year-wise identification of material, was held to suffer from a fatal jurisdictional defect. The Tribunal held that the assessee could challenge the validity of the foundational assessment in appeal against the revision order, and that the original assessment was void in law because valid jurisdiction under the search assessment provisions had not been assumed for the year in question. As the foundational assessment was unsustainable, the revisionary order under section 263 could not survive and was set aside.
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