Scope of intermediary status for data hosting services: tribunal finds provider not intermediary, services exported and not taxable, limited remand on...
CENVAT credit availability after omission of Rule 12B in textiles confirmed; late addendum to SCN introducing new grounds held time-barred and invalid...
Export of Wheat Flour and related products subject to online allocation, eligibility criteria, non-transferable six-month authorisations and reporting...
Straight-line lease rental accounting change results in penalty quashed where disclosed accounts and bona fide arguable accounting interpretation exis...
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The dominant issue was whether the limitation for passing the final assessment order in a DRP case is governed by section 153(1) read with section 153(4) or by section 144C(13). Relying on coordinate bench precedent that followed HC rulings, the Tribunal held that statutory limitation must be computed under section 153(1) r/w section 153(4), fixing the last permissible date as 30.09.2021. Since the final assessment order was passed on 07.07.2023, it was held to be time-barred and was quashed, resulting in allowance of the taxpayer's appeal. - ITAT
The dominant issue was whether the limitation for passing the final assessment order in a DRP case is governed by section 153(1) read with section 153(4) or by section 144C(13). Relying on coordinate bench precedent that followed HC rulings, the Tribunal held that statutory limitation must be computed under section 153(1) r/w section 153(4), fixing the last permissible date as 30.09.2021. Since the final assessment order was passed on 07.07.2023, it was held to be time-barred and was quashed, resulting in allowance of the taxpayer's appeal. - ITAT
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