Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by ...
Imported menthol-scented sweet supari classification dispute: seizure quashed, release for home consumption subject to duty bond; bank guarantee refus...
CKD/SKD air-conditioner components classifiable with finished units by essential character; prior advance ruling extended three years, FTA benefits po...
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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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