Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
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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.
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