Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Assessment u/s 153C - inordinate delay in commencement of proceedings - The High court rejected the argument that the proceedings for AYs 2014-15 to 2016-17 were barred by limitation. It clarified that Section 153C, read with Section 153A, allows for assessment or reassessment for six years preceding the search year and for relevant assessment years beyond that, thus encompassing the years in question. - The court found that a consolidated Satisfaction Note suffices the requirements of Section 153C, provided it contains particulars of the incriminating material relevant to the block of AYs. It was determined that the respondents had collated substantial evidence warranting further scrutiny under the Act.
Assessment u/s 153C - inordinate delay in commencement of proceedings - The High court rejected the argument that the proceedings for AYs 2014-15 to 2016-17 were barred by limitation. It clarified that Section 153C, read with Section 153A, allows for assessment or reassessment for six years preceding the search year and for relevant assessment years beyond that, thus encompassing the years in question. - The court found that a consolidated Satisfaction Note suffices the requirements of Section 153C, provided it contains particulars of the incriminating material relevant to the block of AYs. It was determined that the respondents had collated substantial evidence warranting further scrutiny under the Act.
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