Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
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.
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