Personal liberty safeguards restrict arrest after court-directed GST appearance, requiring interim release where authorities overreach pending proceed...
Alternative statutory remedy and delay bar GST writ challenges despite pending rectification, while distinct subject matter permits parallel proceedin...
Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
HC ruled that the Assessing Officer (AO) cannot reopen assessment for AY 2016-17 under Section 153A, as it falls outside the six-year block period following a search action. The notice was invalid because: (1) no asset-related income escape was established, (2) expenses disallowance did not meet statutory criteria for reopening, and (3) the assessment year exceeded the permissible limitation period. The search conducted in FY 2022-23 only allows reassessment for AY 2017-18 through AY 2023-24. Consequently, the HC set aside the impugned notice and terminated the reassessment proceedings.
HC ruled that the Assessing Officer (AO) cannot reopen assessment for AY 2016-17 under Section 153A, as it falls outside the six-year block period following a search action. The notice was invalid because: (1) no asset-related income escape was established, (2) expenses disallowance did not meet statutory criteria for reopening, and (3) the assessment year exceeded the permissible limitation period. The search conducted in FY 2022-23 only allows reassessment for AY 2017-18 through AY 2023-24. Consequently, the HC set aside the impugned notice and terminated the reassessment proceedings.
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