Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
ITAT determined that assessment framed under provisions relating to adjudication under a special dispute resolution mechanism is time-barred due to the interplay of limitation provisions, finding the assessment barred by the limitation regime and consequently quashing the final assessment. The decision notes that the revenue must follow the procedure for an identical question pending before higher courts under the statutory mechanism, and it relies on coordinate bench and High Court precedents to uphold consistency. Parties are granted liberty to revive the appeal if the Supreme Court Larger Bench decision on the limitation issue alters this result.
ITAT determined that assessment framed under provisions relating to adjudication under a special dispute resolution mechanism is time-barred due to the interplay of limitation provisions, finding the assessment barred by the limitation regime and consequently quashing the final assessment. The decision notes that the revenue must follow the procedure for an identical question pending before higher courts under the statutory mechanism, and it relies on coordinate bench and High Court precedents to uphold consistency. Parties are granted liberty to revive the appeal if the Supreme Court Larger Bench decision on the limitation issue alters this result.
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