Service of notice and contractual debt acknowledgment preserved insolvency admission against a corporate guarantor despite limitation and natural just...
Original works exemption excludes standalone boulder transportation, leaving subcontracted railway-project transport services subject to service tax l...
Annual production capacity determinations excluding stenter galleries support refunds for unconstitutional excise levies without an unjust-enrichment ...
Vicarious liability for cheque dishonour requires specific allegations of responsibility and cheque signatory; generic director allegations cannot sus...
IT Resilience Index requires market infrastructure institutions to automate resilience scoring, early warnings, and continuous service-delivery monito...
ITAT set aside reassessment notice u/s 148 dated 28/07/2022 as time-barred. Applying the SC jurisprudence on interplay between pre- and post-TOLA regimes, the Tribunal held that only the balance or "surviving" period available under the Income-tax Act read with TOLA may be used to complete post-deemed-notice steps, including issuance of a fresh s.148 notice. The original notice dated 30/06/2021 operated as a deemed notice; the surviving window ran only from 28/06/2021 to 30/06/2021 (two days). The AO failed to complete s.148A(c)/(d) and issue s.148 within that surviving period after expiry of the assessee's reply deadline, rendering the impugned notice barred by limitation and quashed.
ITAT set aside reassessment notice u/s 148 dated 28/07/2022 as time-barred. Applying the SC jurisprudence on interplay between pre- and post-TOLA regimes, the Tribunal held that only the balance or "surviving" period available under the Income-tax Act read with TOLA may be used to complete post-deemed-notice steps, including issuance of a fresh s.148 notice. The original notice dated 30/06/2021 operated as a deemed notice; the surviving window ran only from 28/06/2021 to 30/06/2021 (two days). The AO failed to complete s.148A(c)/(d) and issue s.148 within that surviving period after expiry of the assessee's reply deadline, rendering the impugned notice barred by limitation and quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
