Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by ...
Imported menthol-scented sweet supari classification dispute: seizure quashed, release for home consumption subject to duty bond; bank guarantee refus...
CKD/SKD air-conditioner components classifiable with finished units by essential character; prior advance ruling extended three years, FTA benefits po...
Scope of judicial review under Article 226: supervisory, not appellate; factual reappraisal barred, challenge dismissed; insolvency professional dutie...
ITAT dismissed the assessee's appeal and upheld the PCIT's revisional order u/s 263. It held that the reassessment order dated 30.03.2023 was an "order" independent of the original assessment and was within the limitation period prescribed in s.263(2), hence not barred by limitation. Adequate opportunity of hearing was found to have been afforded through multiple notices and written submissions, satisfying the requirement of s.263, including by electronic mode as per s.2(23C). The AO's failure to disallow delayed employees' PF/ESI contributions, contrary to s.36(1)(va) and binding precedent, rendered the reassessment order both erroneous and prejudicial to the revenue. The ground on customs duty fine/penalty was not pressed and stood rejected.
ITAT dismissed the assessee's appeal and upheld the PCIT's revisional order u/s 263. It held that the reassessment order dated 30.03.2023 was an "order" independent of the original assessment and was within the limitation period prescribed in s.263(2), hence not barred by limitation. Adequate opportunity of hearing was found to have been afforded through multiple notices and written submissions, satisfying the requirement of s.263, including by electronic mode as per s.2(23C). The AO's failure to disallow delayed employees' PF/ESI contributions, contrary to s.36(1)(va) and binding precedent, rendered the reassessment order both erroneous and prejudicial to the revenue. The ground on customs duty fine/penalty was not pressed and stood rejected.
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