Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
For assessment years beginning on or before 1 April 2021, the first proviso to section 149(1) retains the limitation period under the erstwhile reassessment regime as a threshold bar. A reassessment notice for AY 2015-16, issued after the applicable six-year period had expired, was therefore time-barred. Compliance with section 148A and any exclusion or extension under the former third and fourth provisos to section 149(1) could not revive a notice prohibited by the first proviso. The ITAT quashed the reassessment notice and consequential reassessment order; other grounds became academic.
For assessment years beginning on or before 1 April 2021, the first proviso to section 149(1) retains the limitation period under the erstwhile reassessment regime as a threshold bar. A reassessment notice for AY 2015-16, issued after the applicable six-year period had expired, was therefore time-barred. Compliance with section 148A and any exclusion or extension under the former third and fourth provisos to section 149(1) could not revive a notice prohibited by the first proviso. The ITAT quashed the reassessment notice and consequential reassessment order; other grounds became academic.
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