Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
Benami property exclusion from the insolvency estate: Benami Act proceedings preclude IBC tribunals from reopening attachments or treating such assets...
Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
Issue: Whether interest under section 234A is leviable where the original return was belated but a return filed in response to a section 153C notice was timely. Reasoning: Section 234A(1) charges interest for delay in filing the original return based on tax as determined under section 143(1) or a regular assessment; Explanation 3 treats an assessment made for the first time under section 153A (including assessments pursuant to section 153C) as a regular assessment for section 234A purposes. Outcome: Interest under section 234A was correctly computed and sustained. - ITAT
Issue: Whether interest under section 234A is leviable where the original return was belated but a return filed in response to a section 153C notice was timely. Reasoning: Section 234A(1) charges interest for delay in filing the original return based on tax as determined under section 143(1) or a regular assessment; Explanation 3 treats an assessment made for the first time under section 153A (including assessments pursuant to section 153C) as a regular assessment for section 234A purposes. Outcome: Interest under section 234A was correctly computed and sustained. - ITAT
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