Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
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Reassessment for AY 2017-18 was held within limitation because the earlier notice issued on 29.04.2021 was treated as a deemed notice under section 148A(b) in light of Union of India v. Ashish Agarwal and Union of India v. Rajeev Bansal. The Court held that the saving of defences under section 149 did not help the assessee, as the notice remained issuable under the old regime up to 31.03.2024 where escaped income crossed the applicable threshold. It further held that alleged escaped income exceeding Rs. 50 lakhs and represented as immovable property attracted the extended ten-year period. The challenge to the order under section 148A(d), the consequential notice under section 148, and the assessment order on limitation grounds was rejected and the writ petition dismissed.
Reassessment for AY 2017-18 was held within limitation because the earlier notice issued on 29.04.2021 was treated as a deemed notice under section 148A(b) in light of Union of India v. Ashish Agarwal and Union of India v. Rajeev Bansal. The Court held that the saving of defences under section 149 did not help the assessee, as the notice remained issuable under the old regime up to 31.03.2024 where escaped income crossed the applicable threshold. It further held that alleged escaped income exceeding Rs. 50 lakhs and represented as immovable property attracted the extended ten-year period. The challenge to the order under section 148A(d), the consequential notice under section 148, and the assessment order on limitation grounds was rejected and the writ petition dismissed.
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