Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
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The Tribunal held that the extended reassessment period beyond three years was unavailable because the alleged escaped income related only to a claimed donation deduction and did not meet the statutory monetary threshold for extension. It further found that, even after excluding the time allowed to respond to the section 148A(b) notice, the Assessing Officer had time only until 07/04/2023 to issue the reassessment notice, but it was issued on 10/04/2023. The sixth proviso was therefore inapplicable, and the reassessment notice was time-barred and invalid; the merits of the disallowance were left open.
The Tribunal held that the extended reassessment period beyond three years was unavailable because the alleged escaped income related only to a claimed donation deduction and did not meet the statutory monetary threshold for extension. It further found that, even after excluding the time allowed to respond to the section 148A(b) notice, the Assessing Officer had time only until 07/04/2023 to issue the reassessment notice, but it was issued on 10/04/2023. The sixth proviso was therefore inapplicable, and the reassessment notice was time-barred and invalid; the merits of the disallowance were left open.
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