Classification of imported salvaged shaft pieces as ship parts confirmed, reassessment time-barred and appeal allowed restoring original classificatio...
Scope of intermediary status for data hosting services: tribunal finds provider not intermediary, services exported and not taxable, limited remand on...
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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