Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Proceedings under section 153C were held without jurisdiction for A.Y. 2014-15 because the satisfaction note dated 31.05.2023 fixed A.Y. 2024-25 as the reckoning year, so the ten-year block could reach back only to A.Y. 2015-16 and not earlier; the notice and assessment for A.Y. 2014-15 were quashed. For A.Ys. 2015-16 and 2016-17, the Tribunal held that satisfaction recorded after 01.04.2021 could not sustain section 153C action against the other person, and proceedings ought to have been initiated under section 148 instead; the section 153C proceedings were quashed and the remaining grounds were left academic.
Proceedings under section 153C were held without jurisdiction for A.Y. 2014-15 because the satisfaction note dated 31.05.2023 fixed A.Y. 2024-25 as the reckoning year, so the ten-year block could reach back only to A.Y. 2015-16 and not earlier; the notice and assessment for A.Y. 2014-15 were quashed. For A.Ys. 2015-16 and 2016-17, the Tribunal held that satisfaction recorded after 01.04.2021 could not sustain section 153C action against the other person, and proceedings ought to have been initiated under section 148 instead; the section 153C proceedings were quashed and the remaining grounds were left academic.
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