Personal liberty safeguards restrict arrest after court-directed GST appearance, requiring interim release where authorities overreach pending proceed...
Alternative statutory remedy and delay bar GST writ challenges despite pending rectification, while distinct subject matter permits parallel proceedin...
Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Notice issued for reopening assessment u/s 147 was beyond the limitation period stipulated in Section 149(1). The High Court, following Ojjus Medicare Pvt. Limited, clarified the manner of reckoning the six or ten-year period for reopening assessment prior to six years or before expiry of ten years from the relevant assessment year u/s 153C. The court held that the ten-year period is to be reckoned from the end of the assessment year relevant to the year in which the notice u/s 148 is issued. Consequently, the impugned notice for Assessment Year 2015-16 was set aside, restraining the respondent from proceeding with the reassessment proceedings.
Notice issued for reopening assessment u/s 147 was beyond the limitation period stipulated in Section 149(1). The High Court, following Ojjus Medicare Pvt. Limited, clarified the manner of reckoning the six or ten-year period for reopening assessment prior to six years or before expiry of ten years from the relevant assessment year u/s 153C. The court held that the ten-year period is to be reckoned from the end of the assessment year relevant to the year in which the notice u/s 148 is issued. Consequently, the impugned notice for Assessment Year 2015-16 was set aside, restraining the respondent from proceeding with the reassessment proceedings.
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