Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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The ITAT held that the limitation period for issuing a notice u/s 143(2) is relevant to the financial year and assessment year. When the Assessing Officer considered the return of income after rectification for initiating assessment proceedings, the relevant date for initiation dates back to the original date of filing the return of income. Therefore, the time limit for issuing the notice u/s 143(2) must be considered from the date of filing the original return of income. Following the decision in SMC COMTRADE LTD. VERSUS ASST. COMMISSIONER OF INCOME-TAX, CIRCLE 24 (1), the Tribunal treated the notice issued u/s 143(2) as invalid. Consequently, further proceedings initiated based on the invalid notice were held to be bad in law, and the assessment order passed on the basis of the invalid notice was quashed. The assessee's appeal was allowed.
The ITAT held that the limitation period for issuing a notice u/s 143(2) is relevant to the financial year and assessment year. When the Assessing Officer considered the return of income after rectification for initiating assessment proceedings, the relevant date for initiation dates back to the original date of filing the return of income. Therefore, the time limit for issuing the notice u/s 143(2) must be considered from the date of filing the original return of income. Following the decision in SMC COMTRADE LTD. VERSUS ASST. COMMISSIONER OF INCOME-TAX, CIRCLE 24 (1), the Tribunal treated the notice issued u/s 143(2) as invalid. Consequently, further proceedings initiated based on the invalid notice were held to be bad in law, and the assessment order passed on the basis of the invalid notice was quashed. The assessee's appeal was allowed.
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