Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Proceeds of crime: provisional attachment confirmed; equivalent value attachment and acquisition date fair market value upheld, Covid exclusion preser...
Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
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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