Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Section 153C jurisdiction requires a valid, year-specific satisfaction note identifying seized material belonging to or relating to the assessee and its bearing on income. A consolidated note based only on surrender letters does not satisfy this requirement, as surrender letters are not seized material. The six-year assessment block is reckoned from the deemed search year; years outside that block cannot be assessed under section 153C. Years within the block must be assessed through section 153C rather than regular assessment proceedings. For completed, unabated assessments, additions require incriminating material found during search; a change in revenue-recognition method without such material cannot support an addition.
Section 153C jurisdiction requires a valid, year-specific satisfaction note identifying seized material belonging to or relating to the assessee and its bearing on income. A consolidated note based only on surrender letters does not satisfy this requirement, as surrender letters are not seized material. The six-year assessment block is reckoned from the deemed search year; years outside that block cannot be assessed under section 153C. Years within the block must be assessed through section 153C rather than regular assessment proceedings. For completed, unabated assessments, additions require incriminating material found during search; a change in revenue-recognition method without such material cannot support an addition.
Note: It is a system-generated summary and is for quick reference only.