Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by ...
Imported menthol-scented sweet supari classification dispute: seizure quashed, release for home consumption subject to duty bond; bank guarantee refus...
CKD/SKD air-conditioner components classifiable with finished units by essential character; prior advance ruling extended three years, FTA benefits po...
Scope of judicial review under Article 226: supervisory, not appellate; factual reappraisal barred, challenge dismissed; insolvency professional dutie...
For search-related reassessment, the HC held that the six-year block under section 153A and the extended ten-year block under Explanation 1 use different computation methods, and the language of the ten-year provision requires the search assessment year to be included as the first year in the reckoning. On that construction, a search conducted in FY 2023-24 made AY 2024-25 the first year and AY 2015-16 the tenth year, so AY 2014-15 fell outside the permissible period. The Court followed its earlier view and rejected the Revenue's contrary interpretation, quashing the section 148 notice for AY 2014-15 as time-barred.
For search-related reassessment, the HC held that the six-year block under section 153A and the extended ten-year block under Explanation 1 use different computation methods, and the language of the ten-year provision requires the search assessment year to be included as the first year in the reckoning. On that construction, a search conducted in FY 2023-24 made AY 2024-25 the first year and AY 2015-16 the tenth year, so AY 2014-15 fell outside the permissible period. The Court followed its earlier view and rejected the Revenue's contrary interpretation, quashing the section 148 notice for AY 2014-15 as time-barred.
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