Person chargeable with duty must be the importer at importation; subsequent purchasers cannot be held liable where beneficial owner rules did not appl...
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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