Condonation of Delay denied: communication lapses and corporate restructuring found insufficient; prolonged inaction and lack of bona fides led to ref...
Export Support intervention INSIGHT launched to provide non financial capacity building, trade intelligence and pilot support with defined funding and...
The article explains that the Finance Act 2020 amendment (effective 01.04.2020) expanded the definition of "eligible assessee" in Section 144C(15)(b) to include non-resident individuals, so the petitioner (an NRI) qualified as an eligible assessee at the time of the Section 148 notice; proceedings before the Dispute Resolution Panel under Section 144C extended limitation via Section 153, and the petitioner's post hoc Section 154 rectification was treated as an afterthought. The court found estoppel by the petitioner's conduct (including filing objections) and refused the challenge to jurisdiction absent a Transfer Order under Section 127, dismissing the writ petition.
The article explains that the Finance Act 2020 amendment (effective 01.04.2020) expanded the definition of "eligible assessee" in Section 144C(15)(b) to include non-resident individuals, so the petitioner (an NRI) qualified as an eligible assessee at the time of the Section 148 notice; proceedings before the Dispute Resolution Panel under Section 144C extended limitation via Section 153, and the petitioner's post hoc Section 154 rectification was treated as an afterthought. The court found estoppel by the petitioner's conduct (including filing objections) and refused the challenge to jurisdiction absent a Transfer Order under Section 127, dismissing the writ petition.
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