Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
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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