Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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For reassessment notices issued more than three years after the end of the relevant assessment year, section 151(ii) requires approval from the statutorily specified authority rather than the Principal Commissioner. The notes state that the later proviso to section 151, effective from 1 April 2023 and allowing exclusion of time permitted for a reply under section 148A(b), operates prospectively and does not validate an earlier notice. Approval by an incompetent authority is a jurisdictional defect, not a defect in form, authentication or communication curable under section 292BC. On that basis, the reassessment for AY 2018-19 was quashed, with other contentions left open.
For reassessment notices issued more than three years after the end of the relevant assessment year, section 151(ii) requires approval from the statutorily specified authority rather than the Principal Commissioner. The notes state that the later proviso to section 151, effective from 1 April 2023 and allowing exclusion of time permitted for a reply under section 148A(b), operates prospectively and does not validate an earlier notice. Approval by an incompetent authority is a jurisdictional defect, not a defect in form, authentication or communication curable under section 292BC. On that basis, the reassessment for AY 2018-19 was quashed, with other contentions left open.
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