Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
The ITAT held that the reassessment notice u/s 148 for AY 2014-15 and AY 2015-16 was time-barred. For AY 2014-15, the assessee failed to respond within the two-week period specified in the show cause notice, rendering the 28.07.2022 notice invalid. For AY 2015-16, the notice was issued beyond the six-year limitation period, expiring on 31.03.2022. Consequently, the tribunal quashed both reassessment notices and subsequent proceedings as bad in law, dismissing the revenue's grounds of appeal and upholding the limitation bar established by judicial precedents.
The ITAT held that the reassessment notice u/s 148 for AY 2014-15 and AY 2015-16 was time-barred. For AY 2014-15, the assessee failed to respond within the two-week period specified in the show cause notice, rendering the 28.07.2022 notice invalid. For AY 2015-16, the notice was issued beyond the six-year limitation period, expiring on 31.03.2022. Consequently, the tribunal quashed both reassessment notices and subsequent proceedings as bad in law, dismissing the revenue's grounds of appeal and upholding the limitation bar established by judicial precedents.
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