Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Reopening for A.Y. 2015-16 was challenged on the ground that a notice under s.148 issued after 1 April 2021 was impermissible under the post-Finance Act 2021 regime and the Revenue's own concession before the SC that such notices must be dropped. Applying that concession, and noting that the impugned s.148 notice was dated 23 April 2022, the reopening lacked legal basis; consequently, the s.148 notice and all consequential proceedings, including the assessment order, demand, penalty actions, and recovery steps, were quashed and set aside. - HC
Reopening for A.Y. 2015-16 was challenged on the ground that a notice under s.148 issued after 1 April 2021 was impermissible under the post-Finance Act 2021 regime and the Revenue's own concession before the SC that such notices must be dropped. Applying that concession, and noting that the impugned s.148 notice was dated 23 April 2022, the reopening lacked legal basis; consequently, the s.148 notice and all consequential proceedings, including the assessment order, demand, penalty actions, and recovery steps, were quashed and set aside. - HC
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