Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
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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