Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Customs valuation and classification require comparable evidence and assessment of imported goods in their actual condition, invalidating related pena...
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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