Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
The Tribunal held that an unchallenged BIFR order disposing of MA No. 442/2011 attained finality, so the company could not reopen a claim for entry tax exemption after that proceeding ended. It further held that there was no deemed consent by the State to the rehabilitation scheme's tax concession clause because the State had expressly ? no, must be English. The State had expressly refused consent during objections to the draft scheme, so Clause 20 was not binding on it under SICA. The Tribunal also held that no relief could be founded on the invalid Central Government notification of 24 May 2017, and the NCLT correctly rejected the petition for exemption.
The Tribunal held that an unchallenged BIFR order disposing of MA No. 442/2011 attained finality, so the company could not reopen a claim for entry tax exemption after that proceeding ended. It further held that there was no deemed consent by the State to the rehabilitation scheme's tax concession clause because the State had expressly ? no, must be English. The State had expressly refused consent during objections to the draft scheme, so Clause 20 was not binding on it under SICA. The Tribunal also held that no relief could be founded on the invalid Central Government notification of 24 May 2017, and the NCLT correctly rejected the petition for exemption.
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