Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
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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