Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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.
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