Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Reopening of assessment u/s 147 - period of limitation - The High Court observed that, the three-year time period of A.Y 2016-17 had ended on 31.03.2020. Accordingly, the Impugned Notice, dated 21.07.2022, is beyond 3 years’ time period. Further, the said notice is for alleged escaped income a sum which is less than Rs. 50,00,000/- and thus, the said notice cannot take the benefit of extended period of limitation which is beyond three years till ten years. - Accordingly, the HC held that, the Notice is illegal, unsustainable and void ab initio and is liable to be set-aside.
Reopening of assessment u/s 147 - period of limitation - The High Court observed that, the three-year time period of A.Y 2016-17 had ended on 31.03.2020. Accordingly, the Impugned Notice, dated 21.07.2022, is beyond 3 years’ time period. Further, the said notice is for alleged escaped income a sum which is less than Rs. 50,00,000/- and thus, the said notice cannot take the benefit of extended period of limitation which is beyond three years till ten years. - Accordingly, the HC held that, the Notice is illegal, unsustainable and void ab initio and is liable to be set-aside.
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