Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
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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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