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...
Tribunal power to admit belated additional grounds was upheld where those grounds go to the root of the dispute and all relevant facts are already on record; accordingly the tribunal admitted the assessee's additional ground. Reopening of assessment was held invalid because the reassessment was initiated solely on specified cash deposits yet the assessing officer made an unrelated addition by disallowing an exemption that was not part of the recorded reasons for reopening; since the addition did not flow from the recorded reasons, the reopening was quashed and the appeal allowed.
Tribunal power to admit belated additional grounds was upheld where those grounds go to the root of the dispute and all relevant facts are already on record; accordingly the tribunal admitted the assessee's additional ground. Reopening of assessment was held invalid because the reassessment was initiated solely on specified cash deposits yet the assessing officer made an unrelated addition by disallowing an exemption that was not part of the recorded reasons for reopening; since the addition did not flow from the recorded reasons, the reopening was quashed and the appeal allowed.
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