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...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Threshold for allottee-initiated insolvency petitions in leasehold real estate upheld; petition admitted after possession letters deemed legally ineff...
Contravention of foreign exchange rules in crossborder diamond payments; appellate tribunal reduces one appellant's penalty for delay and proportional...
Reopening of assessment is time barred where the assessee filed a return and disclosed all material facts; audit objections that merely note absence of justification in the file do not constitute fresh information to initiate reassessment if the assessing officer already possessed the relevant documents. Consequently, under the pre 1 April 2021 scheme the extended six year period is unavailable and reassessment notices issued beyond four years from the end of the assessment year are invalid; the notice dated 31.03.2023 and subsequent proceedings are therefore barred by limitation.
Reopening of assessment is time barred where the assessee filed a return and disclosed all material facts; audit objections that merely note absence of justification in the file do not constitute fresh information to initiate reassessment if the assessing officer already possessed the relevant documents. Consequently, under the pre 1 April 2021 scheme the extended six year period is unavailable and reassessment notices issued beyond four years from the end of the assessment year are invalid; the notice dated 31.03.2023 and subsequent proceedings are therefore barred by limitation.
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