Advance-ruling mechanism governs pending GST classification, exemption and taxability disputes, limiting writ review once the specialised forum functi...
Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
For assessment year 2015-16, a reassessment notice issued under section 148 on 15.04.2022 was held time-barred because it was issued after six years from the end of the assessment year. The Tribunal followed the jurisdictional High Court's view that, for assessment years beginning on or before 01.04.2021, the first proviso to section 149 preserves the earlier limitation bar and the amended ten-year reopening period cannot operate retrospectively to revive a barred case. It also held that the exclusion provisions for time spent in section 148A proceedings do not override that limitation bar. The reassessment was therefore quashed.
For assessment year 2015-16, a reassessment notice issued under section 148 on 15.04.2022 was held time-barred because it was issued after six years from the end of the assessment year. The Tribunal followed the jurisdictional High Court's view that, for assessment years beginning on or before 01.04.2021, the first proviso to section 149 preserves the earlier limitation bar and the amended ten-year reopening period cannot operate retrospectively to revive a barred case. It also held that the exclusion provisions for time spent in section 148A proceedings do not override that limitation bar. The reassessment was therefore quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
