Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
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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