Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
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Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
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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