Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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Validity of Reopening of assessment - period of limitation - Although the notice dated 30.06.2021 u/s 148 bears an endorsement at the foot of the page that it has been digitally signed, it is inchoate, in the sense that it is not accompanied by a date. - Admittedly, the said notice was never physically delivered to the assessee. As such, the fact remains that service of the said notice u/s 148 was affected on the petitioner only on 16.07.2021 through email, though the limitation period had already expired on 30.06.2021. - HC
Validity of Reopening of assessment - period of limitation - Although the notice dated 30.06.2021 u/s 148 bears an endorsement at the foot of the page that it has been digitally signed, it is inchoate, in the sense that it is not accompanied by a date. - Admittedly, the said notice was never physically delivered to the assessee. As such, the fact remains that service of the said notice u/s 148 was affected on the petitioner only on 16.07.2021 through email, though the limitation period had already expired on 30.06.2021. - HC
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