Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Assessment proceedings u/s 153C - The period of limitation and deemed date for possession of seized documents were discussed. It was held that the date of recording satisfaction would be the deemed date for possession of seized documents, which was 03-10-2022, and six years would be reckoned from this date. The submission made by the Authorized Representative was tenable, and the relevant assessment year for the previous year in which the search was conducted would be AY 2023-24, with six immediately preceding assessment years being AY 2018-19 to 2022-23. The assessment for AY 2021-22 should have been carried out by issuing notice u/s 153C and not Section 143(2). The case was covered by the Akanksha Gupta case, and the assessment order passed u/s 143(3) was held to be bad in law and liable to be quashed. The assessee's appeal was allowed.
Assessment proceedings u/s 153C - The period of limitation and deemed date for possession of seized documents were discussed. It was held that the date of recording satisfaction would be the deemed date for possession of seized documents, which was 03-10-2022, and six years would be reckoned from this date. The submission made by the Authorized Representative was tenable, and the relevant assessment year for the previous year in which the search was conducted would be AY 2023-24, with six immediately preceding assessment years being AY 2018-19 to 2022-23. The assessment for AY 2021-22 should have been carried out by issuing notice u/s 153C and not Section 143(2). The case was covered by the Akanksha Gupta case, and the assessment order passed u/s 143(3) was held to be bad in law and liable to be quashed. The assessee's appeal was allowed.
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