Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
For reopening beyond three years, the statutory threshold under section 149(1)(b) must be met by material showing escaped income of Rs. 50 lakhs or more. The Tribunal held that the reopening was initiated on incorrect or non-existing portal information, because the assessment ultimately treated only Rs. 17,17,597 as unexplained after verification and explanation by the assessee. As the case did not satisfy the extended-limitation condition, it fell within section 149(1)(a) and the notice under section 148 issued beyond three years was invalid. The consequential reassessment order under section 147 read with section 144B was quashed as void ab initio.
For reopening beyond three years, the statutory threshold under section 149(1)(b) must be met by material showing escaped income of Rs. 50 lakhs or more. The Tribunal held that the reopening was initiated on incorrect or non-existing portal information, because the assessment ultimately treated only Rs. 17,17,597 as unexplained after verification and explanation by the assessee. As the case did not satisfy the extended-limitation condition, it fell within section 149(1)(a) and the notice under section 148 issued beyond three years was invalid. The consequential reassessment order under section 147 read with section 144B was quashed as void ab initio.
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