Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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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