Withdrawal of obsolete FEMA circulars streamlines rules on external commercial borrowings, non-resident bond investments, and money transfer sub-agent...
Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
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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