Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
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For AY 2015-16, reassessment notices issued after expiry of the earlier six-year limitation could not be revived under the amended regime. The exclusion and extension in the fifth and sixth provisos were confined to computing limitation under the amended provision and did not dilute the absolute bar created by the first proviso where the notice had already become time-barred. A notice issued on 07/04/2022 was therefore beyond the surviving limitation and without jurisdiction, and the consequential reassessment was quashed.
For AY 2015-16, reassessment notices issued after expiry of the earlier six-year limitation could not be revived under the amended regime. The exclusion and extension in the fifth and sixth provisos were confined to computing limitation under the amended provision and did not dilute the absolute bar created by the first proviso where the notice had already become time-barred. A notice issued on 07/04/2022 was therefore beyond the surviving limitation and without jurisdiction, and the consequential reassessment was quashed.
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