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...
Under section 144C(13), the limitation for passing the final assessment order runs from the month in which DRP directions are received. The text states that the directions were uploaded on the ITBA portal and emailed to the AO on 27.06.2024, with delivery established on that date; therefore receipt occurred electronically then, not later on physical delivery. On that basis, the limitation expired on 31.07.2024, and the assessment order passed on 27.08.2024 was time-barred and quashed; the remaining grounds were left academic.
Under section 144C(13), the limitation for passing the final assessment order runs from the month in which DRP directions are received. The text states that the directions were uploaded on the ITBA portal and emailed to the AO on 27.06.2024, with delivery established on that date; therefore receipt occurred electronically then, not later on physical delivery. On that basis, the limitation expired on 31.07.2024, and the assessment order passed on 27.08.2024 was time-barred and quashed; the remaining grounds were left academic.
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