Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
For assessment years beginning on or before 1 April 2021, the first proviso to section 149(1) preserves the pre-Finance Act 2021 limitation for reassessment notices. The note states that a notice for AY 2016-17 issued after the earlier six-year period was time-barred, rendering the reassessment and consequential assessment invalid. It further addresses additions under section 68 on sale proceeds of unquoted shares: where acquisition, holding and sale were supported by banking records, balance-sheet disclosures, sale bills and purchaser confirmations, and no evidence linked the assessee to an alleged cash trail, sale proceeds could not be treated as unexplained cash credit. An ad hoc profit addition without substantive material was also deleted.
For assessment years beginning on or before 1 April 2021, the first proviso to section 149(1) preserves the pre-Finance Act 2021 limitation for reassessment notices. The note states that a notice for AY 2016-17 issued after the earlier six-year period was time-barred, rendering the reassessment and consequential assessment invalid. It further addresses additions under section 68 on sale proceeds of unquoted shares: where acquisition, holding and sale were supported by banking records, balance-sheet disclosures, sale bills and purchaser confirmations, and no evidence linked the assessee to an alleged cash trail, sale proceeds could not be treated as unexplained cash credit. An ad hoc profit addition without substantive material was also deleted.
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