Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Section 153C jurisdiction for assessment years beyond the six preceding years requires the Assessing Officer to record satisfaction that escaped income is represented by an asset. The six-year period is reckoned from the assessment year relevant to the previous year in which seized material is received by the Assessing Officer having jurisdiction over the other person; on that basis, AY 2015-16 fell within the extended period. However, a satisfaction note referring only to alleged cash transactions did not establish the mandatory asset-representation condition. The assessment was therefore treated as void for lack of valid jurisdiction, and the consequential addition could not survive; issues concerning digital evidence, consolidated satisfaction and merits remained open.
Section 153C jurisdiction for assessment years beyond the six preceding years requires the Assessing Officer to record satisfaction that escaped income is represented by an asset. The six-year period is reckoned from the assessment year relevant to the previous year in which seized material is received by the Assessing Officer having jurisdiction over the other person; on that basis, AY 2015-16 fell within the extended period. However, a satisfaction note referring only to alleged cash transactions did not establish the mandatory asset-representation condition. The assessment was therefore treated as void for lack of valid jurisdiction, and the consequential addition could not survive; issues concerning digital evidence, consolidated satisfaction and merits remained open.
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