Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Reopening of assessment v/s assessment u/s 153C - The Appellate Tribunal acknowledged the argument presented by the appellant and emphasized the importance of applying Section 153C when incriminating material pertaining to a person other than the searched party is found. Citing relevant judicial precedents, including decisions from the Supreme Court and High Courts, the Tribunal concluded that the AO should have initiated proceedings under Section 153C instead of Section 147. As the AO failed to present any additional information beyond the seized documents, the Tribunal deemed the assessment order void-ab-initio and upheld the appellant's contention regarding the invalidity of the notice issued under Section 148.
Reopening of assessment v/s assessment u/s 153C - The Appellate Tribunal acknowledged the argument presented by the appellant and emphasized the importance of applying Section 153C when incriminating material pertaining to a person other than the searched party is found. Citing relevant judicial precedents, including decisions from the Supreme Court and High Courts, the Tribunal concluded that the AO should have initiated proceedings under Section 153C instead of Section 147. As the AO failed to present any additional information beyond the seized documents, the Tribunal deemed the assessment order void-ab-initio and upheld the appellant's contention regarding the invalidity of the notice issued under Section 148.
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