Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Validity of initiation of proceedings u/s 148 - what cannot be done directly cannot be done indirectly - If any material was found relating to the assessee during the course of search on third parties then the correct course of action would have been to proceed against the assessee under section 153C of the Act and there was no justification for the A.O. to initiate the proceedings under section 147 r.w.s 148 of the Act. - AT
Validity of initiation of proceedings u/s 148 - what cannot be done directly cannot be done indirectly - If any material was found relating to the assessee during the course of search on third parties then the correct course of action would have been to proceed against the assessee under section 153C of the Act and there was no justification for the A.O. to initiate the proceedings under section 147 r.w.s 148 of the Act. - AT
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