Drawings/designs supply and erection supervision fees from German contractor: designs non-taxable; supervision taxed as FTS/PE depending on six-month ...
Imported analyser diagnostic cartridges treated as accessories with analyser system, not standalone diagnostic reagents; extended limitation and penal...
Steel-timber construction shuttering/formwork tariff classification dispute: essential character held steel, classified as shuttering under Heading 73...
ITAT allowed the assessee's appeal and quashed the reassessment proceedings. It held that for AY 2013-14, the statutory time limit for issuing notice u/s 148 expired on 31.03.2020, whereas the AO issued notice on 16.04.2021, rendering it time-barred and invalid. Further, sanction for issuance of notice was obtained from the PCIT instead of the competent authority, the PCCIT, vitiating the proceedings. The Tribunal held that such foundational defects in jurisdiction and sanction are not curable u/s 292BB, and consequently the reassessment was invalid.
ITAT allowed the assessee's appeal and quashed the reassessment proceedings. It held that for AY 2013-14, the statutory time limit for issuing notice u/s 148 expired on 31.03.2020, whereas the AO issued notice on 16.04.2021, rendering it time-barred and invalid. Further, sanction for issuance of notice was obtained from the PCIT instead of the competent authority, the PCCIT, vitiating the proceedings. The Tribunal held that such foundational defects in jurisdiction and sanction are not curable u/s 292BB, and consequently the reassessment was invalid.
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