Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
The ITAT held that the order passed by the Commissioner of Income Tax (Appeals) [CIT(E)] u/s 263 of the Income Tax Act was quashed. The notice issued u/s 263 was not validly served on the assessee, either through registered post or email, before the hearing date. The notices were served only after the hearing date, violating the principles of natural justice. Additionally, the CIT(E)'s order was passed after the two-year limitation period prescribed u/s 263(2) had expired. Relying on the judgments of M L Chains and Tulsi Tracom (P) Ltd., the ITAT ruled in favor of the assessee, quashing the CIT(E)'s order due to invalid service of notice and the expiry of the limitation period.
The ITAT held that the order passed by the Commissioner of Income Tax (Appeals) [CIT(E)] u/s 263 of the Income Tax Act was quashed. The notice issued u/s 263 was not validly served on the assessee, either through registered post or email, before the hearing date. The notices were served only after the hearing date, violating the principles of natural justice. Additionally, the CIT(E)'s order was passed after the two-year limitation period prescribed u/s 263(2) had expired. Relying on the judgments of M L Chains and Tulsi Tracom (P) Ltd., the ITAT ruled in favor of the assessee, quashing the CIT(E)'s order due to invalid service of notice and the expiry of the limitation period.
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