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...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
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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