Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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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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