Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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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