Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Validity of Assessment u/s 153C - The period of six years would have to be reckoned with respect to the date of recording of satisfaction note, not the date of search. The court concluded that assessments made for AY 2012-13 u/s 144 r.w.s. 142(1), consequent to the satisfaction note recorded on 18.11.2013 (AY 2014-15), ought to have been made u/s 153C. Since the provisions of Section 153C were not invoked, the assessment made u/s 144 r.w.s. 142(1) is treated as void ab initio.
Validity of Assessment u/s 153C - The period of six years would have to be reckoned with respect to the date of recording of satisfaction note, not the date of search. The court concluded that assessments made for AY 2012-13 u/s 144 r.w.s. 142(1), consequent to the satisfaction note recorded on 18.11.2013 (AY 2014-15), ought to have been made u/s 153C. Since the provisions of Section 153C were not invoked, the assessment made u/s 144 r.w.s. 142(1) is treated as void ab initio.
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