Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
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...
The first proviso to section 149(1) preserves the earlier reassessment limitation for assessment years beginning on or before 1 April 2021. It prevents notice under the amended regime where notice was already time-barred under the pre-Finance Act 2021 limits. For A.Y. 2015-16, the note identifies expiry of the former six-year period on 31 March 2022; therefore, a section 148 notice issued thereafter is treated as time-barred, rendering the consequential reassessment unsustainable.
The first proviso to section 149(1) preserves the earlier reassessment limitation for assessment years beginning on or before 1 April 2021. It prevents notice under the amended regime where notice was already time-barred under the pre-Finance Act 2021 limits. For A.Y. 2015-16, the note identifies expiry of the former six-year period on 31 March 2022; therefore, a section 148 notice issued thereafter is treated as time-barred, rendering the consequential reassessment unsustainable.
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