Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
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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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