Effective hearing in GST adjudication requires actual opportunity to respond; ineffective service through a former auditor invalidated ex parte procee...
Third-party search material requires special assessment route, rendering general reassessment notices without jurisdiction when it forms the proceedin...
Transfer-pricing adjustments must be confined to international associated-enterprise transactions, while functionally dissimilar comparables remain ex...
Insolvency moratorium bars income-tax revision proceedings against corporate debtors until the moratorium ends, preserving merits for later determinat...
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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