Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Computation of limitation for reopening after a search must treat the six-year block and the ten-year outer limit differently: the six-year period is computed with reference to the assessment year relevant to the previous year in which the search occurred, while the ten-year outer limit is reckoned backwards from the end of that assessment year. Applying this method to a search on 04.03.2022 places AY 2013-14 as the tenth year and excludes AY 2012-13; consequently a notice issued under the reopening provision for AY 2012-13 was held time-barred and quashed.
Computation of limitation for reopening after a search must treat the six-year block and the ten-year outer limit differently: the six-year period is computed with reference to the assessment year relevant to the previous year in which the search occurred, while the ten-year outer limit is reckoned backwards from the end of that assessment year. Applying this method to a search on 04.03.2022 places AY 2013-14 as the tenth year and excludes AY 2012-13; consequently a notice issued under the reopening provision for AY 2012-13 was held time-barred and quashed.
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