Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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The High Court held that the impugned notice issued u/s 148 of the Act was beyond the time limitation prescribed u/s 149(1). The Revenue's contention that the non-obstante clause u/s 150 permitted issuance of the notice, premised on the assumption that the High Court's previous order dismissing the Revenue's appeal contained findings and directions for commencing proceedings u/s 147, was rejected. The Court clarified that its previous order could not be construed as permitting reopening of assessments beyond the period stipulated u/s 149(1) or where necessary conditions for invoking Sections 147 and 148 were not satisfied. Consequently, the time limitation u/s 149(1) was applicable, rendering the impugned notice invalid.
The High Court held that the impugned notice issued u/s 148 of the Act was beyond the time limitation prescribed u/s 149(1). The Revenue's contention that the non-obstante clause u/s 150 permitted issuance of the notice, premised on the assumption that the High Court's previous order dismissing the Revenue's appeal contained findings and directions for commencing proceedings u/s 147, was rejected. The Court clarified that its previous order could not be construed as permitting reopening of assessments beyond the period stipulated u/s 149(1) or where necessary conditions for invoking Sections 147 and 148 were not satisfied. Consequently, the time limitation u/s 149(1) was applicable, rendering the impugned notice invalid.
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