Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Assumption of jurisdiction under 153C - assessment in search cases - Even as per the pre-amended provisions of Section 153C, AO has to record satisfaction to the effect that seized material "belongs" or "belongs to" other person. In this case, the A.O. has not put on record that any material seized during the course of search does belong to the assessee. However seized materials related to other third party. Therefore in our considered view, the invocation of proceedings u/s. 153C is against the provisions of law. - AT
Assumption of jurisdiction under 153C - assessment in search cases - Even as per the pre-amended provisions of Section 153C, AO has to record satisfaction to the effect that seized material "belongs" or "belongs to" other person. In this case, the A.O. has not put on record that any material seized during the course of search does belong to the assessee. However seized materials related to other third party. Therefore in our considered view, the invocation of proceedings u/s. 153C is against the provisions of law. - AT
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