Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
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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