Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Page of 4809
Press 'Enter' after typing page number.
1381 to 1400 of 96176 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
HC held that a rectification order under Section 154(7) cannot be passed after four years from the end of the financial year in which the original order was made. As the original order was dated February 25, 2015, the limitation expired on March 31, 2019, but the rectification order was issued on March 25, 2022; it was therefore time-barred and a jurisdictional error. The Court also noted that the Department had not shown service of prior notice under Section 154(3), and accepted the objection that the order lacked a Document Identification Number. The writ petition was allowed and the rectification order, together with consequential recovery proceedings, was set aside.
HC held that a rectification order under Section 154(7) cannot be passed after four years from the end of the financial year in which the original order was made. As the original order was dated February 25, 2015, the limitation expired on March 31, 2019, but the rectification order was issued on March 25, 2022; it was therefore time-barred and a jurisdictional error. The Court also noted that the Department had not shown service of prior notice under Section 154(3), and accepted the objection that the order lacked a Document Identification Number. The writ petition was allowed and the rectification order, together with consequential recovery proceedings, was set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
