Cash routed to non-existent firm deemed proceeds of crime; laundered funds and properties attachable, provisional attachments confirmed; two accounts ...
Continuation of Section 73 service-tax proceedings after provider's death (construing s.65(7)) - held to abate; posthumous OIO and recoveries invalida...
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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