Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
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Once the original reassessment orders u/s 148 were quashed, they ceased to exist legally. The rectification order u/s 154 was premised on the quashed orders, which could not be revived or corrected. Section 154 could only be invoked if a valid order capable of rectification existed. Since the original orders were non-existent after being quashed, invoking Section 154 was impermissible. Additionally, the condition u/s 149(1)(b) requiring income escaping assessment to be Rs. 50 lakhs or more was not fulfilled. Consequently, the rectification order was unsustainable and quashed by the High Court.
Once the original reassessment orders u/s 148 were quashed, they ceased to exist legally. The rectification order u/s 154 was premised on the quashed orders, which could not be revived or corrected. Section 154 could only be invoked if a valid order capable of rectification existed. Since the original orders were non-existent after being quashed, invoking Section 154 was impermissible. Additionally, the condition u/s 149(1)(b) requiring income escaping assessment to be Rs. 50 lakhs or more was not fulfilled. Consequently, the rectification order was unsustainable and quashed by the High Court.
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