Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Personal hearing requirements in GST adjudication were satisfied by prior opportunities and written submissions; appellate limitation received writ-pe...
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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