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...
The text clarifies computation of limitation for reassessment following a search: the statutory language creates two distinct periods - a six-assessment-year window that excludes the assessment year corresponding to the previous year of the search, and a separate ten-assessment-year outer limit that is reckoned from the end of the search assessment year and therefore includes that year as the first of the ten. Applying this construction, the ten-year outer limit can render reopening for a specified assessment year time-barred; accordingly, notices issued beyond that ten-year block were held invalid in the described instance.
The text clarifies computation of limitation for reassessment following a search: the statutory language creates two distinct periods - a six-assessment-year window that excludes the assessment year corresponding to the previous year of the search, and a separate ten-assessment-year outer limit that is reckoned from the end of the search assessment year and therefore includes that year as the first of the ten. Applying this construction, the ten-year outer limit can render reopening for a specified assessment year time-barred; accordingly, notices issued beyond that ten-year block were held invalid in the described instance.
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