Condonation of delay in filing GSTR-3B returns and entitlement to Section 62 benefit results in withdrawal of assessments and revocation of attachment...
Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
The Tribunal held that the limitation challenge could be decided despite pendency before the Supreme Court because the assessees relied on an unstayed precedent. Reading sections 144C and 153 together, it rejected the Revenue's contention that limitation for a final assessment order under section 144C(13) must be tested only under section 144C. Applying the Roca Bathroom Products line of reasoning, it found the impugned final assessment orders for the relevant assessment years were passed beyond the permissible period and therefore barred by limitation. The orders were quashed, and the remaining grounds were left open.
The Tribunal held that the limitation challenge could be decided despite pendency before the Supreme Court because the assessees relied on an unstayed precedent. Reading sections 144C and 153 together, it rejected the Revenue's contention that limitation for a final assessment order under section 144C(13) must be tested only under section 144C. Applying the Roca Bathroom Products line of reasoning, it found the impugned final assessment orders for the relevant assessment years were passed beyond the permissible period and therefore barred by limitation. The orders were quashed, and the remaining grounds were left open.
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