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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
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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
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