Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
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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