Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Pre-existing disputes over outcome-based professional fees can bar Section 9 insolvency proceedings where contractual entitlement requires investigati...
Corresponding scheduled offences preserve money-laundering jurisdiction despite repeal of the central corruption provision where conduct remains cover...
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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TaxTMI 
TaxTMI 
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