Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Section 154 rectification applications must be filed within four years from the end of the financial year in which the order sought to be amended was passed. The notes state that section 154(7) is clear and unambiguous and contains no provision allowing condonation of delay for reasonable cause. On a literal construction, expiry of this period removes the authority's jurisdiction to entertain a rectification application, including applications seeking correction of income returned and processed under section 143(1). Accordingly, the delayed applications were treated as time-barred, their rejection was upheld, and the related appeals were dismissed.
Section 154 rectification applications must be filed within four years from the end of the financial year in which the order sought to be amended was passed. The notes state that section 154(7) is clear and unambiguous and contains no provision allowing condonation of delay for reasonable cause. On a literal construction, expiry of this period removes the authority's jurisdiction to entertain a rectification application, including applications seeking correction of income returned and processed under section 143(1). Accordingly, the delayed applications were treated as time-barred, their rejection was upheld, and the related appeals were dismissed.
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