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...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
The HC held that DRP directions uploaded to the ITBA portal with a DIN on 26.05.2022 constitute receipt by the assessing officer for limitation purposes under section 144C(13). Uploading ipso facto effects service; physical speed-post receipt on 01.06.2022 was inconsequential. Consequently the one-month limitation period expired on 30.06.2022 and the assessment order passed on 01.07.2022 is time-barred and therefore invalid. The court rejected the Revenue's contention that international taxation matters fall outside electronic communication, noting DRP directions were uploaded by the Revenue and electronic service under the e-Assessment Scheme governs computation of limitation. No substantial question of law arises.
The HC held that DRP directions uploaded to the ITBA portal with a DIN on 26.05.2022 constitute receipt by the assessing officer for limitation purposes under section 144C(13). Uploading ipso facto effects service; physical speed-post receipt on 01.06.2022 was inconsequential. Consequently the one-month limitation period expired on 30.06.2022 and the assessment order passed on 01.07.2022 is time-barred and therefore invalid. The court rejected the Revenue's contention that international taxation matters fall outside electronic communication, noting DRP directions were uploaded by the Revenue and electronic service under the e-Assessment Scheme governs computation of limitation. No substantial question of law arises.
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