Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
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Under the amended reassessment regime, a notice for reopening cannot survive if the case had already become time-barred under the old law. On the facts stated, the relevant assessment year remained within the earlier six-year period, and the time between the section 148A(b) notice and the assessee's reply had to be excluded for limitation; the section 148A(d) order and section 148 notice were therefore within time. The escaped income had not been part of the earlier scrutiny assessment, so the limitation challenge failed and the other objections were left open.
Under the amended reassessment regime, a notice for reopening cannot survive if the case had already become time-barred under the old law. On the facts stated, the relevant assessment year remained within the earlier six-year period, and the time between the section 148A(b) notice and the assessee's reply had to be excluded for limitation; the section 148A(d) order and section 148 notice were therefore within time. The escaped income had not been part of the earlier scrutiny assessment, so the limitation challenge failed and the other objections were left open.
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