Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
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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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