Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Under Section 144C the Dispute Resolution Panel (DRP) should have dismissed the petitioner's objections simpliciter because a final assessment order had already been passed; therefore the DRP's findings on whether the objections were intimated to the assessing officer were unwarranted. The operative effect directed is that those DRP observations shall not be considered by the Commissioner of Income Tax (Appeals), who must decide the taxpayer's appeal against the final assessment order without being influenced by the impugned DRP order.
Under Section 144C the Dispute Resolution Panel (DRP) should have dismissed the petitioner's objections simpliciter because a final assessment order had already been passed; therefore the DRP's findings on whether the objections were intimated to the assessing officer were unwarranted. The operative effect directed is that those DRP observations shall not be considered by the Commissioner of Income Tax (Appeals), who must decide the taxpayer's appeal against the final assessment order without being influenced by the impugned DRP order.
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