Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
SC held that the Limitation Act applies comprehensively to recovery proceedings. Section 18 permits limitation period extension when liability is acknowledged, particularly where payment time has not yet matured. The respondents' technical objections were deemed dilatory, as they were aware of previous judicial determinations. The High Court's order was set aside, with writ petitions to be restored and heard after disposal of pending intra-court appeals. The limitation period for recovery proceedings was effectively extended due to respondents' liability acknowledgment, enabling the appellant to pursue legal remedies within prescribed timelines.
SC held that the Limitation Act applies comprehensively to recovery proceedings. Section 18 permits limitation period extension when liability is acknowledged, particularly where payment time has not yet matured. The respondents' technical objections were deemed dilatory, as they were aware of previous judicial determinations. The High Court's order was set aside, with writ petitions to be restored and heard after disposal of pending intra-court appeals. The limitation period for recovery proceedings was effectively extended due to respondents' liability acknowledgment, enabling the appellant to pursue legal remedies within prescribed timelines.
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