COVID-19 limitation exclusion and destination-specific e-way bills govern revisional timelines and penalties for undocumented third-party plywood deli...
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...
Search-assessment limitation requires court-ordered stay periods to be excluded within the single composite limitation period before testing whether TOLA extends that date. Treating the stay exclusion as an addition after a TOLA extension would improperly enlarge the period available for completing assessments. For years affected by the stay, the composite limitation date fell outside the TOLA window; for the remaining years, the extension operated only until 30 September 2021. The assessments, related notices and consequential penalty proceedings for all nine assessment years were time-barred and quashed, while the merits of the additions remained open.
Search-assessment limitation requires court-ordered stay periods to be excluded within the single composite limitation period before testing whether TOLA extends that date. Treating the stay exclusion as an addition after a TOLA extension would improperly enlarge the period available for completing assessments. For years affected by the stay, the composite limitation date fell outside the TOLA window; for the remaining years, the extension operated only until 30 September 2021. The assessments, related notices and consequential penalty proceedings for all nine assessment years were time-barred and quashed, while the merits of the additions remained open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
