Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengea...
Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Consequential assessment orders giving effect to appellate directions that require verification and an opportunity to the assessee must be completed within the limitation period applicable under section 153(3), as extended by TOLA where relevant. Where the appellate order was received during FY 2019-20, the consequential order had to be made by 31 March 2022. An order issued after that date is time-barred and cannot support a demand notice. In the absence of a valid fresh assessment, the returned income must be accepted, and amounts deposited against the invalid demand are refundable with interest.
Consequential assessment orders giving effect to appellate directions that require verification and an opportunity to the assessee must be completed within the limitation period applicable under section 153(3), as extended by TOLA where relevant. Where the appellate order was received during FY 2019-20, the consequential order had to be made by 31 March 2022. An order issued after that date is time-barred and cannot support a demand notice. In the absence of a valid fresh assessment, the returned income must be accepted, and amounts deposited against the invalid demand are refundable with interest.
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