Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Interplay between limitation for passing final assessment under section 144C(13) and section 153 is examined; the analysis applies the principle that provisions are to be read together where they are inter-dependent and overlapping, particularly regarding transfer pricing related provisions, and therefore the applicable limitation period must be determined with reference to section 144C read with section 153; consequence: final assessment orders issued beyond that combined limitation period are jurisdictionally infirm and were quashed following the precedent relied upon.
Interplay between limitation for passing final assessment under section 144C(13) and section 153 is examined; the analysis applies the principle that provisions are to be read together where they are inter-dependent and overlapping, particularly regarding transfer pricing related provisions, and therefore the applicable limitation period must be determined with reference to section 144C read with section 153; consequence: final assessment orders issued beyond that combined limitation period are jurisdictionally infirm and were quashed following the precedent relied upon.
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