Unlawful outward remittances via Hawala using proforma invoices and electronic records proved; documents admitted, directors penalised, penalties redu...
Attachment of equivalent-value properties as proceeds of crime upheld; preventive attachment order and confirmation sustained; no independent ED reinv...
Broker trading-system "technical glitch" redefinition and narrowed incident-reporting regime for large IBT/STWT brokers requiring 2-hr notice and 14-w...
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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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