Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
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...
Reasonable time limit for issuing notice u/s 201(1)/201(1A) is 4 years, as held in GE India Technology Centre and Mahindra & Mahindra Ltd. judgments. Where notice is issued beyond 4 years, it is barred by limitation u/s 201(1). In the present case, orders are beyond 4 years from the end of the financial year, hence unsustainable and quashed. The entire proceeding arose from a belated and unsustainable survey u/s 133A(2A) conducted on 09/12/2019, which is quashed. Non-resident income is clearly time-barred, while resident income transaction did not crystallize. Assessee's appeal allowed.
Reasonable time limit for issuing notice u/s 201(1)/201(1A) is 4 years, as held in GE India Technology Centre and Mahindra & Mahindra Ltd. judgments. Where notice is issued beyond 4 years, it is barred by limitation u/s 201(1). In the present case, orders are beyond 4 years from the end of the financial year, hence unsustainable and quashed. The entire proceeding arose from a belated and unsustainable survey u/s 133A(2A) conducted on 09/12/2019, which is quashed. Non-resident income is clearly time-barred, while resident income transaction did not crystallize. Assessee's appeal allowed.
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