Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
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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