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...
Threshold for allottee-initiated insolvency petitions in leasehold real estate upheld; petition admitted after possession letters deemed legally ineff...
Contravention of foreign exchange rules in crossborder diamond payments; appellate tribunal reduces one appellant's penalty for delay and proportional...
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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