Blocked input tax credit for resort construction remains unavailable; interest follows actual utilisation, while delayed payment attracts statutory pe...
Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
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The first proviso to section 153C shifts the commencement of the six- and ten-year assessment block for a non-searched person from the search date to the date on which that person's jurisdictional Assessing Officer receives the seized material. Applying this legal fiction, satisfaction notes and notice issued in FY 2021-22 made AY 2022-23 the relevant year, limiting the ten-year block to AYs 2013-14 through 2022-23. AY 2012-13 therefore fell outside the permissible period, rendering its assessment invalid and resulting in dismissal of the Revenue's appeal. The parties remain bound by the outcome of the pending SLP concerning the governing precedent.
The first proviso to section 153C shifts the commencement of the six- and ten-year assessment block for a non-searched person from the search date to the date on which that person's jurisdictional Assessing Officer receives the seized material. Applying this legal fiction, satisfaction notes and notice issued in FY 2021-22 made AY 2022-23 the relevant year, limiting the ten-year block to AYs 2013-14 through 2022-23. AY 2012-13 therefore fell outside the permissible period, rendering its assessment invalid and resulting in dismissal of the Revenue's appeal. The parties remain bound by the outcome of the pending SLP concerning the governing precedent.
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