Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
For computing limitation for a final assessment after DRP directions, the operative date is the date the directions are intimated and uploaded on the ITBA portal with DIN, because that upload constitutes communication and receipt by the Assessing Officer. The Tribunal rejected the Revenue's contention that time should run only from later physical receipt of the directions. Applying that rule, the final assessment orders were passed beyond the prescribed period and were therefore time-barred and invalid. The orders were quashed, and the appeals were partly allowed, with other issues left open.
For computing limitation for a final assessment after DRP directions, the operative date is the date the directions are intimated and uploaded on the ITBA portal with DIN, because that upload constitutes communication and receipt by the Assessing Officer. The Tribunal rejected the Revenue's contention that time should run only from later physical receipt of the directions. Applying that rule, the final assessment orders were passed beyond the prescribed period and were therefore time-barred and invalid. The orders were quashed, and the appeals were partly allowed, with other issues left open.
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