Form 26AS evidence requires successor-entity accounting verification after business transfer, while invoice-supported related-party advertising expend...
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Accredited investor eligibility expands through securities-market exposure, while alternative investment fund disputes require prescribed resolution a...
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Reopening notices for years before AY 2021-22 could be issued after the 01.04.2021 amendment only if the pre-existing six-year limitation under section 149 was still alive on the date of notice. Applying the principle in UOI v. Rajiv Bansal and following Sridhar Lokesh, the Tribunal held that the first proviso bars retrospective use of the extended ten-year period; for AY 2015-16, the outer limit expired on 31.03.2022, so a notice issued on 01.04.2022 was time-barred. It further held that exclusion of time spent in section 148A proceedings could not revive a notice already barred under the first proviso. The reassessment was quashed and the additions were deleted.
Reopening notices for years before AY 2021-22 could be issued after the 01.04.2021 amendment only if the pre-existing six-year limitation under section 149 was still alive on the date of notice. Applying the principle in UOI v. Rajiv Bansal and following Sridhar Lokesh, the Tribunal held that the first proviso bars retrospective use of the extended ten-year period; for AY 2015-16, the outer limit expired on 31.03.2022, so a notice issued on 01.04.2022 was time-barred. It further held that exclusion of time spent in section 148A proceedings could not revive a notice already barred under the first proviso. The reassessment was quashed and the additions were deleted.
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