Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
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The Income Tax Appellate Tribunal (ITAT) held that the reassessment notices issued u/s 148 of the Income Tax Act for the assessment years 2013-14, 2014-15, and 2015-16 were barred by limitation and quashed them. The Tribunal relied on the Supreme Court's judgment in Union of India vs. Ashish Agarwal, which clarified the applicability of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA). The TOLA extended the time limit for issuing reassessment notices until June 30, 2021, for proceedings pending between March 21, 2020, and March 31, 2021. However, in the present case, the reassessment notices were issued after June 30, 2021, for the assessment years 2013-14 and 2014-15, and after the expiry of the limitation period u/s 149(1) for the assessment year 2015-16. Consequently, the ITAT dismissed the Revenue's appeals and upheld the quashing of the reassessment notices.
The Income Tax Appellate Tribunal (ITAT) held that the reassessment notices issued u/s 148 of the Income Tax Act for the assessment years 2013-14, 2014-15, and 2015-16 were barred by limitation and quashed them. The Tribunal relied on the Supreme Court's judgment in Union of India vs. Ashish Agarwal, which clarified the applicability of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA). The TOLA extended the time limit for issuing reassessment notices until June 30, 2021, for proceedings pending between March 21, 2020, and March 31, 2021. However, in the present case, the reassessment notices were issued after June 30, 2021, for the assessment years 2013-14 and 2014-15, and after the expiry of the limitation period u/s 149(1) for the assessment year 2015-16. Consequently, the ITAT dismissed the Revenue's appeals and upheld the quashing of the reassessment notices.
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