Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The assessment year in question falls beyond the stipulated six assessment years and four relevant assessment years, rendering the notice issued by the Assessing Officer u/s 153C of the Act, dated 31.12.2021, and the consequent assessment order passed u/s 143(3) read with Section 153C, dated 31.03.2022, barred by limitation. Following the decision of the Honorable Supreme Court in the case of CIT vs Jasjit Singh, for the purpose of the proviso to Section 153C(1) of the Act, in the case of such other person, the reference to the date of initiation of search u/s 132 of the Act in the second proviso to Section 153A(1) shall be construed as the date of receiving the books of accounts or other documents by the Assessing Officer having jurisdiction over such other person, which is considered as 31.12.2021 in the present case. Consequently, the assessment order passed by the Assessing Officer u/s 143(3) read with Section 153C, dated 31.03.2022, is quashed, and the decision is in favor of the assessee.
The assessment year in question falls beyond the stipulated six assessment years and four relevant assessment years, rendering the notice issued by the Assessing Officer u/s 153C of the Act, dated 31.12.2021, and the consequent assessment order passed u/s 143(3) read with Section 153C, dated 31.03.2022, barred by limitation. Following the decision of the Honorable Supreme Court in the case of CIT vs Jasjit Singh, for the purpose of the proviso to Section 153C(1) of the Act, in the case of such other person, the reference to the date of initiation of search u/s 132 of the Act in the second proviso to Section 153A(1) shall be construed as the date of receiving the books of accounts or other documents by the Assessing Officer having jurisdiction over such other person, which is considered as 31.12.2021 in the present case. Consequently, the assessment order passed by the Assessing Officer u/s 143(3) read with Section 153C, dated 31.03.2022, is quashed, and the decision is in favor of the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
