Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
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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TaxTMI 
TaxTMI 
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