Sufficient cause for delayed revenue income-tax appeals requires bona fides, due diligence and a credible explanation; otherwise limitation bars appea...
Inverted-duty-structure refunds remain available for unchanged-rate apparel supplies despite trader status and require tax-period-specific computation...
Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
For a non-searched person, the block period for assessment under section 153C is computed from the date seized material is handed over to, or satisfaction is recorded by, the Assessing Officer having jurisdiction over that person, rather than from the search date. Applying that rule, the relevant assessment years fell outside the permissible period, making the assessments time-barred and depriving the Assessing Officer of valid jurisdiction. ITAT upheld the relief granted to the non-searched person and dismissed the Revenue's appeals, following Supreme Court and High Court precedent.
For a non-searched person, the block period for assessment under section 153C is computed from the date seized material is handed over to, or satisfaction is recorded by, the Assessing Officer having jurisdiction over that person, rather than from the search date. Applying that rule, the relevant assessment years fell outside the permissible period, making the assessments time-barred and depriving the Assessing Officer of valid jurisdiction. ITAT upheld the relief granted to the non-searched person and dismissed the Revenue's appeals, following Supreme Court and High Court precedent.
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