Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
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The Income Tax Appellate Tribunal examined the validity of assessments made u/s 153C, considering the gap between the satisfaction note recorded by the Assessing Officer of the searched person and the jurisdictional Assessing Officer. The Tribunal relied on the Supreme Court's decision in Jasjit Singh's case, which held that the first proviso to Section 153C(1) applies not only to the question of abatement but also to the date from which the six-year period is reckoned for filing returns by third parties. In the present appeals, the requisition and satisfaction note were recorded by the jurisdictional Assessing Officer on 10/11/2021 for the Assessment Year 2022-23. The 10-year outer ceiling limit prescribed in the statute must be computed backward from 31/03/2022. The assessments framed for the Assessment Years 2011-12 and 2012-13 fell beyond this 10-year period contemplated u/s 153C(1). Consequently, the Tribunal decided in favor of the assessee.
The Income Tax Appellate Tribunal examined the validity of assessments made u/s 153C, considering the gap between the satisfaction note recorded by the Assessing Officer of the searched person and the jurisdictional Assessing Officer. The Tribunal relied on the Supreme Court's decision in Jasjit Singh's case, which held that the first proviso to Section 153C(1) applies not only to the question of abatement but also to the date from which the six-year period is reckoned for filing returns by third parties. In the present appeals, the requisition and satisfaction note were recorded by the jurisdictional Assessing Officer on 10/11/2021 for the Assessment Year 2022-23. The 10-year outer ceiling limit prescribed in the statute must be computed backward from 31/03/2022. The assessments framed for the Assessment Years 2011-12 and 2012-13 fell beyond this 10-year period contemplated u/s 153C(1). Consequently, the Tribunal decided in favor of the assessee.
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