Arm's length agent remuneration prevents further permanent establishment profit attribution when it covers risk-taking functions in internet advertisi...
Proof of independent funds for property acquisition requires reliable evidence when cash transactions support provisional attachment as criminal proce...
Transferred freezer use rights exclude service tax; refundable security deposits are not consideration, and extended limitation requires deliberate su...
Section 153C jurisdiction requires the Assessing Officer of the searched person to record satisfaction and hand over seized material before proceedings against another person commence. Where notices preceded these steps, the jurisdictional condition was absent, rendering the notices and consequential assessments void ab initio and quashed. The material must also pertain to the other person and bear on determination of that person's total income; mere discovery of books, documents or assets is insufficient. A later satisfaction note cannot cure defective initiation or establish the required nexus.
Section 153C jurisdiction requires the Assessing Officer of the searched person to record satisfaction and hand over seized material before proceedings against another person commence. Where notices preceded these steps, the jurisdictional condition was absent, rendering the notices and consequential assessments void ab initio and quashed. The material must also pertain to the other person and bear on determination of that person's total income; mere discovery of books, documents or assets is insufficient. A later satisfaction note cannot cure defective initiation or establish the required nexus.
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