S. 151: Reassessment-Sanction for issue of notice-Approval granted after expiry of three years-SLP delay of 411 days-SLP of revenue was dismissed on account of delay as well as on merits. [S.148, 148A(b), 148A(d), 149(1)(b), Art. 136]
S. 151: Reassessment-Sanction for issue of notice-Approval granted after expiry of three years-SLP delay of 411 days-SLP of revenue was dismissed on account of delay as well as on merits. [S.148, 148A(b), 148A(d), 149(1)(b), Art. 136]
S. 150: Assessment-Order on appeal-Survey-Direction issued by the CIT(A) beyond the limitation period-No assessment or reassessment could be made as the time period prescribed under section 149 had already expired-Assessing Officer could not have reopened assessment in compliance with said direction.[S. 133A, 148, 149, 150(1),250, Art. 226]
S. 149: Reassessment-Time limit for notice-Concession given by Additional Solicitor General (ASG)-Notice under section 148 dated 5-4-2022, and all consequential orders/notices were to be quashed.[S. 148, 149(1)(b),151, Art. 226]
S. 149: Reassessment-Time limit for notice-Concession made by Additional Solicitor General before the Supreme Court as recorded in Rajeev Bansal-Notice being barred by limitation was to be dropped, and consequently reassessment order, demand notice and penalty notices were quashed and set aside. [S. 148, 148A(b), 148A(d), Art. 226]
S. 149: Reassessment-Time limit for notice-Surviving period-date of earlier notice under section 148 read with TOLA up to 30-06-2021, last permissible date for issuance of reassessment notice under section 148 would be 18-06-2022-Notice dated 27-07-2022 issued under section 148 having been issued beyond surviving time was invalid [S. 148, 148A(b), 148A(d), Art. 226]
S. 149: Reassessment-Time limit for notice-Notice dated 30-8-2022 issued under section 148 being issued beyond ‘surviving time’ and hence invalid.[S. 148, 148A(b), 148A(d), Art. 226, Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA).]
S. 149: Reassessment-Time limit for notice-Order of the High Court was affirmed-SLP of the revenue was dismissed as time-barred. [S. 148, 148A(b), 148A(d), Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3, Art. 136]
S. 149: Reassessment-Time limit for notice-SLP delay of 800 and 467 days-SLP of revenue dismissed on account of delay.[S. 148,148A(b) 148A(d), Art. 136]
S. 149: Reassessment-Time limit for notice-last date for service of notice and initiating proceedings under section 148 under unamended provisions was coming to an end on 31-3-2021, but notices had been issued from the office of the Department either on 1-4-2021-SLP of revenue dismissed. [S. 148, Art. 136]
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless assessment-Opportunity of hearing-Notice and order were quashed and set aside. [S. 144B, 148A(b) 148A(d), 151A, Art. 226.]