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...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Proceedings under section 201(1) were held time-barred because earlier TDS communications were only information requests and did not amount to initiation; the first valid show-cause notice was issued in 2010. The Court accepted that the proviso to section 201(3), allowing completion up to 31 March 2011, applied only to already pending proceedings and could not revive a fresh initiation after limitation had expired. As the period for commencing action had run out for the assessment years concerned, no substantial question of law arose and the Revenue's challenge failed. The appeal was dismissed.
Proceedings under section 201(1) were held time-barred because earlier TDS communications were only information requests and did not amount to initiation; the first valid show-cause notice was issued in 2010. The Court accepted that the proviso to section 201(3), allowing completion up to 31 March 2011, applied only to already pending proceedings and could not revive a fresh initiation after limitation had expired. As the period for commencing action had run out for the assessment years concerned, no substantial question of law arose and the Revenue's challenge failed. The appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
