Condonation of Delay: Tribunal directed condonation where rectification proceedings were pursued, ordering merits adjudication after opportunity to be...
Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Grandfathering proviso to Section 149(1)(b) preserves pre-amendment limitation computation for searches after 31.03.2021, so the amended ten-year reopening limit does not retrospectively extend time to reopen years already barred under the old regime; applying that principle the Tribunal found AY 2012-13 time barred. Section 148B is pari materia with prior law and requires prior approval founded on independent application of mind with year-wise appraisal of seized material; mechanical or omnibus approvals without examination of seized material vitiate the approval and render resultant assessments void, leading to quashing of assessments for the affected years.
Grandfathering proviso to Section 149(1)(b) preserves pre-amendment limitation computation for searches after 31.03.2021, so the amended ten-year reopening limit does not retrospectively extend time to reopen years already barred under the old regime; applying that principle the Tribunal found AY 2012-13 time barred. Section 148B is pari materia with prior law and requires prior approval founded on independent application of mind with year-wise appraisal of seized material; mechanical or omnibus approvals without examination of seized material vitiate the approval and render resultant assessments void, leading to quashing of assessments for the affected years.
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