Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
HC held that the notice issued under s.148 was time-barred and jurisdictionally invalid because the six-year surviving period from the end of the relevant assessment year had expired before issuance; the respondent's contention that a ten-year period applied was rejected. The HC found only two days remained to complete the s.148A(d) process and issue a s.148 notice, which in any event expired before the notice dated 27 July 2022. Consequently the impugned s.148 notice and all subsequent communications including notices under s.142(1) and the related show-cause notice were quashed and set aside as beyond jurisdiction. Other contentions of the petitioner were left open.
HC held that the notice issued under s.148 was time-barred and jurisdictionally invalid because the six-year surviving period from the end of the relevant assessment year had expired before issuance; the respondent's contention that a ten-year period applied was rejected. The HC found only two days remained to complete the s.148A(d) process and issue a s.148 notice, which in any event expired before the notice dated 27 July 2022. Consequently the impugned s.148 notice and all subsequent communications including notices under s.142(1) and the related show-cause notice were quashed and set aside as beyond jurisdiction. Other contentions of the petitioner were left open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
