Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Impugned proceedings u/s 147 were held invalid as the notice u/s 148 was issued beyond the time limit prescribed u/s 149. The Tribunal interpreted the amended provisions along with the explanatory memorandum to mean that if the notice was barred by limitation under the erstwhile provisions, it cannot be issued even after the amendment. Consequently, the impugned notice and proceedings were quashed for being initiated beyond the prescribed time limit u/s 149, and the decision was in favor of the assessee.
Impugned proceedings u/s 147 were held invalid as the notice u/s 148 was issued beyond the time limit prescribed u/s 149. The Tribunal interpreted the amended provisions along with the explanatory memorandum to mean that if the notice was barred by limitation under the erstwhile provisions, it cannot be issued even after the amendment. Consequently, the impugned notice and proceedings were quashed for being initiated beyond the prescribed time limit u/s 149, and the decision was in favor of the assessee.
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TaxTMI 
TaxTMI 
of 4888 
