Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
Scientific research association approval requires continuing SIRO status, annual donation reporting, and donor certificates for the approved foundatio...
Scientific research institution approval is conditional on SIRO recognition, annual donation reporting, donor certification, and prescribed compliance...
The HC ruled that for Section 201(1) proceedings the statutory six-year period (adopted as the reasonable yardstick) governs the limitation inquiry, rejecting a blanket seven-year or one-size-fits-all approach and criticizing Revenue delay. Applying the six-year reckoning, the order for AY 2010-11 was set aside as time-barred; the order for AY 2011-12 was held valid as within the limitation period; orders for the remaining assessment years (subsequent four years) were set aside for being passed beyond six years. The court therefore quashed time-barred Section 201 orders and upheld only the order falling within the six-year limitation.
The HC ruled that for Section 201(1) proceedings the statutory six-year period (adopted as the reasonable yardstick) governs the limitation inquiry, rejecting a blanket seven-year or one-size-fits-all approach and criticizing Revenue delay. Applying the six-year reckoning, the order for AY 2010-11 was set aside as time-barred; the order for AY 2011-12 was held valid as within the limitation period; orders for the remaining assessment years (subsequent four years) were set aside for being passed beyond six years. The court therefore quashed time-barred Section 201 orders and upheld only the order falling within the six-year limitation.
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