Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Limitation Period for issuance of notice u/s 143(2) - Scrutiny Assessment - Relevant date - after filing of the return of income, defect notice u/s 139(9) had been sent to the assessee which was cured by the assessee - The ITAT allowed the appeal, holding that the notice issued under Section 143(2) beyond the prescribed time limit rendered the assessment order without jurisdiction and thus, it was quashed. The decision emphasized that the limitation for issuing such a notice runs from the year in which the return of income is filed and not from when a defect, if any, is rectified by the assessee.
Limitation Period for issuance of notice u/s 143(2) - Scrutiny Assessment - Relevant date - after filing of the return of income, defect notice u/s 139(9) had been sent to the assessee which was cured by the assessee - The ITAT allowed the appeal, holding that the notice issued under Section 143(2) beyond the prescribed time limit rendered the assessment order without jurisdiction and thus, it was quashed. The decision emphasized that the limitation for issuing such a notice runs from the year in which the return of income is filed and not from when a defect, if any, is rectified by the assessee.
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