Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Validity of reopening of assessment - doctrine of merger - The ITAT unequivocally quashed the reassessment proceedings initiated against the appellant for the Assessment Year 2006-07, ruling them as bad-in-law due to the procedural flaw of issuing a notice under section 147 beyond the four-year period without specifying the particulars of omitted income - The judgment also indirectly supports the appellant's contention regarding the classification of certain incomes as business incomes eligible for section 80IA deductions, though this specific issue became moot following the quashing of the reassessment order.
Validity of reopening of assessment - doctrine of merger - The ITAT unequivocally quashed the reassessment proceedings initiated against the appellant for the Assessment Year 2006-07, ruling them as bad-in-law due to the procedural flaw of issuing a notice under section 147 beyond the four-year period without specifying the particulars of omitted income - The judgment also indirectly supports the appellant's contention regarding the classification of certain incomes as business incomes eligible for section 80IA deductions, though this specific issue became moot following the quashing of the reassessment order.
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