Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Personal hearing requirements in GST adjudication were satisfied by prior opportunities and written submissions; appellate limitation received writ-pe...
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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