Fair-rent assessment requires consideration of lease terms, valuation principles and prevailing market rent; the certificate was quashed for fresh rev...
Document Identification Number compliance is satisfied when electronically communicated orders are promptly authenticated through a correctly identifi...
Industrial shrimp-feed machinery classification follows its commercial function, placing integrated production plants under the specific industrial fo...
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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