Mark-to-Market losses on principal-protected debentures are deductible as business expenditure when the obligation is crystallized under mercantile ac...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4807
Join Channel
TaxTMI 
