Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Reopening of assessment was held time-barred where a section 148 notice was issued after the pre-amendment six-year limitation, because the first proviso to section 149(1) operates as a substantive restriction preventing issuance of notices for assessment years to which the old regime's period had expired; therefore the reassessment under section 147 read with remedial provisions could not stand. The fifth and sixth provisos, which exclude certain periods for computing limitation under the amended provision, do not extend or revive notices prohibited by the first proviso, so the reassessment was quashed for want of jurisdiction.
Reopening of assessment was held time-barred where a section 148 notice was issued after the pre-amendment six-year limitation, because the first proviso to section 149(1) operates as a substantive restriction preventing issuance of notices for assessment years to which the old regime's period had expired; therefore the reassessment under section 147 read with remedial provisions could not stand. The fifth and sixth provisos, which exclude certain periods for computing limitation under the amended provision, do not extend or revive notices prohibited by the first proviso, so the reassessment was quashed for want of jurisdiction.
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