Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
The key points from the legal text are: Section 153A assessment - Limitation period applies based on when seized materials were handed over to the Assessing Officer (AO), not the search date. Despite 60-day limit in Section 132(9A) for handing over seized assets, non-adherence does not invalidate assessment if within extended limitation u/s 153B(1) proviso. Validity of satisfaction notes u/s 153C - Separate notes recorded for each year, concluding seized materials pertained to assessee and impacted income. Satisfied threshold u/s 153C(1) despite not explicitly mentioning all earlier years. Transfer order u/s 127 - Mixed questions of fact and law involved in determining if consent/consultation requirements were met. No findings recorded due to lack of pleadings. Addition u/s 69 read with 115BBE - Applicable for unexplained investments not recorded in books, even if no books maintained. Computation of income and tax liability upheld.
The key points from the legal text are: Section 153A assessment - Limitation period applies based on when seized materials were handed over to the Assessing Officer (AO), not the search date. Despite 60-day limit in Section 132(9A) for handing over seized assets, non-adherence does not invalidate assessment if within extended limitation u/s 153B(1) proviso. Validity of satisfaction notes u/s 153C - Separate notes recorded for each year, concluding seized materials pertained to assessee and impacted income. Satisfied threshold u/s 153C(1) despite not explicitly mentioning all earlier years. Transfer order u/s 127 - Mixed questions of fact and law involved in determining if consent/consultation requirements were met. No findings recorded due to lack of pleadings. Addition u/s 69 read with 115BBE - Applicable for unexplained investments not recorded in books, even if no books maintained. Computation of income and tax liability upheld.
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