CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
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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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