Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Jurisdictional facts in certificate-of-origin discrepancies can support customs show-cause proceedings, leaving factual explanations for departmental ...
Reopening beyond three years under section 149(1)(b) requires the escaped income to be represented in the form prescribed by law; mere reference to unrecorded scrap-sale receipts and an estimated profit basis was insufficient, so the reassessment for AYs 2019-20 and 2020-21 was quashed. Ambiguous section 148 notices that inconsistently stated the search basis showed non-application of mind, rendering the notices and reassessments for AYs 2021-22 and 2022-23 invalid. For searches conducted after 1 April 2021, the special post-2021 mechanism under sections 147/148, with prior approval under section 148B, prevails over regular assessment under section 143(3); accordingly, the section 143(3) assessments for AYs 2023-24 and 2024-25 were also quashed.
Reopening beyond three years under section 149(1)(b) requires the escaped income to be represented in the form prescribed by law; mere reference to unrecorded scrap-sale receipts and an estimated profit basis was insufficient, so the reassessment for AYs 2019-20 and 2020-21 was quashed. Ambiguous section 148 notices that inconsistently stated the search basis showed non-application of mind, rendering the notices and reassessments for AYs 2021-22 and 2022-23 invalid. For searches conducted after 1 April 2021, the special post-2021 mechanism under sections 147/148, with prior approval under section 148B, prevails over regular assessment under section 143(3); accordingly, the section 143(3) assessments for AYs 2023-24 and 2024-25 were also quashed.
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