Customs valuation and import permissibility conflict resolved: accepted enhancement of transaction value removes liability for confiscation and penalt...
Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
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Assessment orders become effective only when signed, and dating an order within time does not satisfy the statutory limit if signature follows later. The HC held that for AY 2023-24, the limitation under section 153 expired on 31 March 2025, but the assessment order was digitally signed only on 25 December 2025. As the computation sheet and notice of demand were also signed after expiry of limitation, they were not validly made within time. Treating signature as an essential requirement of legal validity, the Court held the assessment order, computation sheet and notice of demand to be time-barred and quashed them.
Assessment orders become effective only when signed, and dating an order within time does not satisfy the statutory limit if signature follows later. The HC held that for AY 2023-24, the limitation under section 153 expired on 31 March 2025, but the assessment order was digitally signed only on 25 December 2025. As the computation sheet and notice of demand were also signed after expiry of limitation, they were not validly made within time. Treating signature as an essential requirement of legal validity, the Court held the assessment order, computation sheet and notice of demand to be time-barred and quashed them.
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