Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
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Assessment u/s 153C - Relevant Date - date on which the AO of the person other than the one searched assumes the possession of the seized assets - The Tribunal's decision emphasized the principle that for initiating proceedings u/s 153C, it is essential to follow the statutory timelines and conditions prescribed under the Income Tax Act. The Tribunal relied on judgments from the Hon'ble High Court and the Supreme Court to conclude that the assessments made for the Assessment Years 2006-07 and 2007-08, based on a satisfaction note recorded, were outside the scope of Section 153C. This led to the conclusion that these assessments were void ab initio, along with the assessment for A.Y. 2012-13. - AT
Assessment u/s 153C - Relevant Date - date on which the AO of the person other than the one searched assumes the possession of the seized assets - The Tribunal's decision emphasized the principle that for initiating proceedings u/s 153C, it is essential to follow the statutory timelines and conditions prescribed under the Income Tax Act. The Tribunal relied on judgments from the Hon'ble High Court and the Supreme Court to conclude that the assessments made for the Assessment Years 2006-07 and 2007-08, based on a satisfaction note recorded, were outside the scope of Section 153C. This led to the conclusion that these assessments were void ab initio, along with the assessment for A.Y. 2012-13. - AT
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