Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
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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