Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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ITAT adjudicated a tax assessment reopening dispute, holding the notice under Section 148 invalid. The AO's notice exceeded statutory time limitations, with escaped income (Rs. 32,92,746) falling below the Rs. 50 lakh threshold required for extended reassessment. Furthermore, the approval was improperly granted by the Principal Commissioner, who lacks jurisdictional authority under Section 151(ii). Consequently, the tribunal set aside the reassessment notice, finding procedural violations in both time limitations and approval process. The assessee's appeal was allowed, effectively nullifying the attempted tax reassessment.
ITAT adjudicated a tax assessment reopening dispute, holding the notice under Section 148 invalid. The AO's notice exceeded statutory time limitations, with escaped income (Rs. 32,92,746) falling below the Rs. 50 lakh threshold required for extended reassessment. Furthermore, the approval was improperly granted by the Principal Commissioner, who lacks jurisdictional authority under Section 151(ii). Consequently, the tribunal set aside the reassessment notice, finding procedural violations in both time limitations and approval process. The assessee's appeal was allowed, effectively nullifying the attempted tax reassessment.
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