Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
A search assessment founded on a single consolidated satisfaction note covering multiple assessment years, without year-wise identification of material, was held to suffer from a fatal jurisdictional defect. The Tribunal held that the assessee could challenge the validity of the foundational assessment in appeal against the revision order, and that the original assessment was void in law because valid jurisdiction under the search assessment provisions had not been assumed for the year in question. As the foundational assessment was unsustainable, the revisionary order under section 263 could not survive and was set aside.
A search assessment founded on a single consolidated satisfaction note covering multiple assessment years, without year-wise identification of material, was held to suffer from a fatal jurisdictional defect. The Tribunal held that the assessee could challenge the validity of the foundational assessment in appeal against the revision order, and that the original assessment was void in law because valid jurisdiction under the search assessment provisions had not been assumed for the year in question. As the foundational assessment was unsustainable, the revisionary order under section 263 could not survive and was set aside.
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