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Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
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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