Transaction value rejection requires reliable corroboration; refundable VAT is excluded and temporary registration does not defeat new-vehicle exempti...
Appellate jurisdiction remains available where a wrist-worn gold ornament cannot conclusively be characterised as imported baggage at the preliminary ...
Written complaint requirement bars cognizance on police reports for securities offences, while unsupported breach of trust and cheating allegations fa...
Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
Customs Cargo Service Provider appointment extends custodianship to additional terminal land, subject to cargo-control, security and licence condition...
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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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