Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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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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