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...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
The High Court addressed the issue of reopening assessment u/s 147 and the time limit for notice u/s 149. The petitioner received a notice u/s 153C after a search operation in 2019, leading to an assessment order in 2023. The petitioner had appealed successfully against disallowances u/s 40(a)(ia) in the original assessment u/s 143(3). A subsequent notice u/s 148 related to a search in 2022, limited to AY 2014-15 per Section 149(1) proviso. Referring to Filatex India Ltd. and Ojjus Medicare Pvt. Ltd., the Court found AY 2013-14 outside the ten-year block period u/s 153C and 153A, making the notice unsustainable.
The High Court addressed the issue of reopening assessment u/s 147 and the time limit for notice u/s 149. The petitioner received a notice u/s 153C after a search operation in 2019, leading to an assessment order in 2023. The petitioner had appealed successfully against disallowances u/s 40(a)(ia) in the original assessment u/s 143(3). A subsequent notice u/s 148 related to a search in 2022, limited to AY 2014-15 per Section 149(1) proviso. Referring to Filatex India Ltd. and Ojjus Medicare Pvt. Ltd., the Court found AY 2013-14 outside the ten-year block period u/s 153C and 153A, making the notice unsustainable.
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