Straight-line lease rental accounting change results in penalty quashed where disclosed accounts and bona fide arguable accounting interpretation exis...
Allocation of enhanced FSI/TDR proceeds between cooperative society and individual flat-owners; tribunal deletes society LTCG addition, remits 80P ver...
The dominant issue was whether the final assessment order under s.143(3) r.w.s.144C(13) was time-barred under s.153(1) read with s.153(4), including the effect of TOLA notifications on the limitation period. Following binding High Court precedents as applied in an earlier co-ordinate bench decision, limitation was computed strictly under s.153(1) r.w.s.153(4); for the relevant AY, the available extended time did not push the deadline beyond 30.09.2021, and an order passed in July 2022 was beyond time. Consequently, the assessment order was quashed as barred by limitation, with liberty to seek revival if the pending larger-bench ruling alters the legal position. - ITAT
The dominant issue was whether the final assessment order under s.143(3) r.w.s.144C(13) was time-barred under s.153(1) read with s.153(4), including the effect of TOLA notifications on the limitation period. Following binding High Court precedents as applied in an earlier co-ordinate bench decision, limitation was computed strictly under s.153(1) r.w.s.153(4); for the relevant AY, the available extended time did not push the deadline beyond 30.09.2021, and an order passed in July 2022 was beyond time. Consequently, the assessment order was quashed as barred by limitation, with liberty to seek revival if the pending larger-bench ruling alters the legal position. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
