Residential waste collection classification under SAC 999423 defeats composite-supply exemption where facilitating goods are not transferred to the lo...
Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
Limitation in customs appeals permits exclusion for bona fide refund proceedings, enabling restoration of Bill of Entry assessment challenges on merit...
Assessment u/s 144C - Period of limitation - The Ld. CIT-DR argued that the delay was due to the assessee's failure to participate in the verification process as directed by the DRP. However, the Tribunal noted that sub-section (8) of section 144C precludes the DRP from setting aside any proposed variation or issuing any direction for further enquiry and passing of the assessment order. The AO was mandated to complete the assessment within the specified time limit without providing any further opportunity of being heard to the assessee. - The Tribunal concluded that the final assessment order passed by the AO was barred by limitation and, therefore, null in the eyes of law.
Assessment u/s 144C - Period of limitation - The Ld. CIT-DR argued that the delay was due to the assessee's failure to participate in the verification process as directed by the DRP. However, the Tribunal noted that sub-section (8) of section 144C precludes the DRP from setting aside any proposed variation or issuing any direction for further enquiry and passing of the assessment order. The AO was mandated to complete the assessment within the specified time limit without providing any further opportunity of being heard to the assessee. - The Tribunal concluded that the final assessment order passed by the AO was barred by limitation and, therefore, null in the eyes of law.
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