Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
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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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