Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
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The first proviso to the limitation provision in section 149(1) restricts retrospective application of the post-2021 ten-year reopening window; for assessment years beginning on or before 1 April 2021 a reopening notice under section 148 is valid only if the pre-2021 (six-year) limitation continued to apply. Applying the Supreme Court ratio in Rajeev Bansal, the court found the six-year period for AY 2013-14 had expired (extended relief aside) before the 2021 amendment took effect, so notices issued in 2024 were time-barred and were quashed.
The first proviso to the limitation provision in section 149(1) restricts retrospective application of the post-2021 ten-year reopening window; for assessment years beginning on or before 1 April 2021 a reopening notice under section 148 is valid only if the pre-2021 (six-year) limitation continued to apply. Applying the Supreme Court ratio in Rajeev Bansal, the court found the six-year period for AY 2013-14 had expired (extended relief aside) before the 2021 amendment took effect, so notices issued in 2024 were time-barred and were quashed.
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