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Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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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