Alternate statutory remedy governs GST assessment challenge, with statutory appeal preserved and limitation objection barred for the permitted filing ...
Assessment u/s 153C - the normal presumption is that document belongs to searched person. It is for the AO to rebut that presumption and come to a conclusion or "satisfaction" that the document in fact belongs to somebody else based on some cogent material - no error much less an error of law could be said to have been committed in taking the view that there is no cogent material for arriving at the substantive satisfaction
Assessment u/s 153C - the normal presumption is that document belongs to searched person. It is for the AO to rebut that presumption and come to a conclusion or "satisfaction" that the document in fact belongs to somebody else based on some cogent material - no error much less an error of law could be said to have been committed in taking the view that there is no cogent material for arriving at the substantive satisfaction
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