Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
A pure legal challenge to a reassessment notice was admitted in cross objection because it went to the root of jurisdiction and had already been raised below. On merits, the ITAT held that a reopening notice issued beyond six years from the end of the relevant assessment year was time-barred. Applying the jurisdictional High Court view, it ruled that the extended reassessment limitation under the amended law operates prospectively and does not revive cases where the old six-year period had already expired. The notice was quashed, the reassessment was invalidated, the assessee's cross objection was allowed, and the Revenue's appeal on merits failed.
A pure legal challenge to a reassessment notice was admitted in cross objection because it went to the root of jurisdiction and had already been raised below. On merits, the ITAT held that a reopening notice issued beyond six years from the end of the relevant assessment year was time-barred. Applying the jurisdictional High Court view, it ruled that the extended reassessment limitation under the amended law operates prospectively and does not revive cases where the old six-year period had already expired. The notice was quashed, the reassessment was invalidated, the assessee's cross objection was allowed, and the Revenue's appeal on merits failed.
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