Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
Penalty u/s 271(1)(c) - non recording of satisfaction - When satisfaction for initiation of penalty proceedings u/s 271(1)(c) of IT Act is recorded by the AO in assessment order in respect of certain additions and not recorded in respect of certain other additions; it acts as a bar against levy of penalty U/s 271(1)(c) in respect of those additions in respect of which such satisfaction was not recorded in the assessment order or during the assessment proceedings
Penalty u/s 271(1)(c) - non recording of satisfaction - When satisfaction for initiation of penalty proceedings u/s 271(1)(c) of IT Act is recorded by the AO in assessment order in respect of certain additions and not recorded in respect of certain other additions; it acts as a bar against levy of penalty U/s 271(1)(c) in respect of those additions in respect of which such satisfaction was not recorded in the assessment order or during the assessment proceedings
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