Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
CBDT guidelines on notice timing under the Black Money Act require a notice for an alleged undisclosed foreign asset to be issued preferably within 30 days after the relevant previous year ends. Although the Act prescribes no statutory limitation period, any departure from the guideline requires recorded written reasons and approval from the competent authority. Where the tax department already possessed and acted on the relevant foreign-asset information, a later notice issued without documented reasons for delay or required approval contravenes the binding guidelines. The notes state that such non-compliance renders the notice time-barred and invalidates the consequential assessment proceedings.
CBDT guidelines on notice timing under the Black Money Act require a notice for an alleged undisclosed foreign asset to be issued preferably within 30 days after the relevant previous year ends. Although the Act prescribes no statutory limitation period, any departure from the guideline requires recorded written reasons and approval from the competent authority. Where the tax department already possessed and acted on the relevant foreign-asset information, a later notice issued without documented reasons for delay or required approval contravenes the binding guidelines. The notes state that such non-compliance renders the notice time-barred and invalidates the consequential assessment proceedings.
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