Managerial remuneration disallowance under s.40A(2)(b) challenged over alleged tax-avoidance; appellate decision restored deletion of addition for dir...
Classification of imported goods as electronic cigarette versus tobacco product reversed for lack of proof; order set aside for jurisdictional overrea...
Reversal of input tax credit in proportion to exempt supply: specificity of show-cause notice required; order set aside, fresh proceedings allowed wit...
The dominant issue was whether the final assessment order passed under s.143(3) read with s.144C(13) was time-barred under s.153(1) read with s.153(4), including the effect of TOLA notifications. Applying the rule of consistency and following an earlier co-ordinate bench decision, it was held that for AY 2018-19 the statutory time limit to complete assessment expired on 30.09.2021 and TOLA did not extend this period for that year. As the final order was passed after the limitation date, it was held to be barred by limitation and was quashed. - ITAT
The dominant issue was whether the final assessment order passed under s.143(3) read with s.144C(13) was time-barred under s.153(1) read with s.153(4), including the effect of TOLA notifications. Applying the rule of consistency and following an earlier co-ordinate bench decision, it was held that for AY 2018-19 the statutory time limit to complete assessment expired on 30.09.2021 and TOLA did not extend this period for that year. As the final order was passed after the limitation date, it was held to be barred by limitation and was quashed. - ITAT
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