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 note addresses whether limitation for passing a final assessment under section 144C(13) must be measured solely by section 144C or with reference to section 153; applying the reasoning of prior precedents it concludes the limitation period is to be determined read with section 153, making the final assessment order u/s 143(3) r.w.s.144C(13) for AY 2020-21 time barred. The operative effect is quashing of that final assessment order. Parties are granted liberty to revive the appeal on merits if the Supreme Court Larger Bench alters the law on this limitation issue.
The note addresses whether limitation for passing a final assessment under section 144C(13) must be measured solely by section 144C or with reference to section 153; applying the reasoning of prior precedents it concludes the limitation period is to be determined read with section 153, making the final assessment order u/s 143(3) r.w.s.144C(13) for AY 2020-21 time barred. The operative effect is quashing of that final assessment order. Parties are granted liberty to revive the appeal on merits if the Supreme Court Larger Bench alters the law on this limitation issue.
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