Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
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The ITAT Amritsar addressed the validity of initiating proceedings u/s 153C(1) instead of 143(3). It was held that initiation of Section 153C occurs upon receiving seized documents by the AO with jurisdiction over the person. The tribunal noted that the initiation u/s 153C(1) was for AY 2021-22, not AY 2020-21, as the documents were handed over on 16-03-2021. Citing precedents like Jasjit Singh and RRJ Securities Ltd, the tribunal deemed the assessment order invalid and quashed it, setting aside the appeal order.
The ITAT Amritsar addressed the validity of initiating proceedings u/s 153C(1) instead of 143(3). It was held that initiation of Section 153C occurs upon receiving seized documents by the AO with jurisdiction over the person. The tribunal noted that the initiation u/s 153C(1) was for AY 2021-22, not AY 2020-21, as the documents were handed over on 16-03-2021. Citing precedents like Jasjit Singh and RRJ Securities Ltd, the tribunal deemed the assessment order invalid and quashed it, setting aside the appeal order.
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