Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
For a non-searched person, the relevant date for section 153C proceedings is the date on which the satisfaction note is recorded or seized material reaches the jurisdictional Assessing Officer. Applying the Supreme Court's ruling in Jasjit Singh and later Tribunal/High Court followings, the Tribunal treated the first proviso to section 153C(1) as governing the operative date for all practical purposes. Because the satisfaction note was recorded after 01.04.2021, section 153C ceased to be available and the proceedings were without jurisdiction. The assessments were therefore held void ab initio and quashed.
For a non-searched person, the relevant date for section 153C proceedings is the date on which the satisfaction note is recorded or seized material reaches the jurisdictional Assessing Officer. Applying the Supreme Court's ruling in Jasjit Singh and later Tribunal/High Court followings, the Tribunal treated the first proviso to section 153C(1) as governing the operative date for all practical purposes. Because the satisfaction note was recorded after 01.04.2021, section 153C ceased to be available and the proceedings were without jurisdiction. The assessments were therefore held void ab initio and quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4786
Join Channel
TaxTMI 
