Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
The Delhi High Court examined the validity of a reassessment action u/s 148, focusing on the time limit for notice u/s 149 and computation of the "relevant assessment year." It was held that AY 2013-14 fell beyond the ten-year block period. The court emphasized the need to consider the statutory scheme for search assessments pre-Finance Act, 2021, and the date of material transmission to the jurisdictional AO for non-searched entities. The court rejected the reconstruction of the "relevant assessment year" point for non-searched persons and found the notice issued on 30 March 2023 to be beyond limitation, thus quashing it and any consequential actions.
The Delhi High Court examined the validity of a reassessment action u/s 148, focusing on the time limit for notice u/s 149 and computation of the "relevant assessment year." It was held that AY 2013-14 fell beyond the ten-year block period. The court emphasized the need to consider the statutory scheme for search assessments pre-Finance Act, 2021, and the date of material transmission to the jurisdictional AO for non-searched entities. The court rejected the reconstruction of the "relevant assessment year" point for non-searched persons and found the notice issued on 30 March 2023 to be beyond limitation, thus quashing it and any consequential actions.
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