Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
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The Income Tax Appellate Tribunal (ITAT) held that the final assessment order passed by the Assessing Officer (AO) u/s 144C(4) read with Section 147 of the Income Tax Act was barred by limitation and void ab initio. The assessee had received the draft assessment order on 27.05.2023, and the due date for filing objections before the Dispute Resolution Panel (DRP) u/s 144C(2) was 26.06.2023. However, the assessee filed the objections on 06.07.2023, beyond the prescribed one-month time limit. Consequently, the AO was mandatorily required to pass the final assessment order by 31.07.2023. However, the AO passed the final order on 04.03.2024, well beyond the prescribed time limit. The ITAT held that by not adhering to the mandatory time limit, the final assessment order was barred by limitation and liable to be quashed.
The Income Tax Appellate Tribunal (ITAT) held that the final assessment order passed by the Assessing Officer (AO) u/s 144C(4) read with Section 147 of the Income Tax Act was barred by limitation and void ab initio. The assessee had received the draft assessment order on 27.05.2023, and the due date for filing objections before the Dispute Resolution Panel (DRP) u/s 144C(2) was 26.06.2023. However, the assessee filed the objections on 06.07.2023, beyond the prescribed one-month time limit. Consequently, the AO was mandatorily required to pass the final assessment order by 31.07.2023. However, the AO passed the final order on 04.03.2024, well beyond the prescribed time limit. The ITAT held that by not adhering to the mandatory time limit, the final assessment order was barred by limitation and liable to be quashed.
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