Clubbing of income from gifted property failed where the claim surfaced after reassessment limitation, sustaining capital-gains assessment in spouse's...
Employee stock-option discount qualifies as revenue expenditure, while royalty and service comparables require reliable functional and transactional b...
Special insurance income computation preserves statutory deductions while limiting transfer-pricing, withholding and disallowance adjustments for gene...
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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TaxTMI 
TaxTMI 
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