Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Under the former reassessment framework, time allowed or extended for an assessee's reply to a Section 148A(b) show-cause notice is excluded when computing the Section 149 limitation period. A notice is not invalid merely because the response period runs beyond the original limitation deadline. After that exclusion, where the remaining time does not exceed seven days, the sixth proviso provides a seven-day terminal period for issuing the Section 148A(d) order and consequential Section 148 notice. The exclusion does not create an open-ended period. Limitation must therefore be computed through the complete chronology of response periods, adjournments, extensions, reply-stage closure, and issuance of both the order and notice.
Under the former reassessment framework, time allowed or extended for an assessee's reply to a Section 148A(b) show-cause notice is excluded when computing the Section 149 limitation period. A notice is not invalid merely because the response period runs beyond the original limitation deadline. After that exclusion, where the remaining time does not exceed seven days, the sixth proviso provides a seven-day terminal period for issuing the Section 148A(d) order and consequential Section 148 notice. The exclusion does not create an open-ended period. Limitation must therefore be computed through the complete chronology of response periods, adjournments, extensions, reply-stage closure, and issuance of both the order and notice.
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TaxTMI 
TaxTMI 
of 4915 
