Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
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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