Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Reassessment under s.147 was challenged on limitation under s.149(1), where the assessee had disclosed complete details of property investment made by her spouse and the alleged escapement did not reach the ₹50 lakh threshold. Applying the statutory scheme and precedent, the forum held that the AO must first demonstrably form a view, from record material, that income chargeable to tax of ₹50 lakh or more escaped assessment to invoke the extended time limit; otherwise, only clause (a) applies. As the assessee established that the escapement assumption exceeding ₹50 lakh was incorrect, the s.148 notice issued beyond three years was invalid and all consequential proceedings were void ab initio. - ITAT
Reassessment under s.147 was challenged on limitation under s.149(1), where the assessee had disclosed complete details of property investment made by her spouse and the alleged escapement did not reach the ₹50 lakh threshold. Applying the statutory scheme and precedent, the forum held that the AO must first demonstrably form a view, from record material, that income chargeable to tax of ₹50 lakh or more escaped assessment to invoke the extended time limit; otherwise, only clause (a) applies. As the assessee established that the escapement assumption exceeding ₹50 lakh was incorrect, the s.148 notice issued beyond three years was invalid and all consequential proceedings were void ab initio. - ITAT
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