Human-probability test defeats political donation deductions where banking records mask accommodation-entry fund layering rather than genuine contribu...
Electronic evidence and search statements in tax assessments require authenticity review and corroboration, while procedural manuals lack statutory fo...
Tariff rate quota authorisations govern preferential imports of specified New Zealand goods through export certification and electronic customs debiti...
Electronic Continuity Bond Registration replaces manual container permissions, with quarterly reporting and re-export monitoring for duty-free contain...
ITAT invalidated assessments under s.153C read with s.153A for AYs 2011-12 and 2012-13. The AO recorded satisfaction note on 25.09.2018, making AY 2019-20 the relevant search assessment year. The years under dispute fell outside jurisdictional scope of revision proceedings. The satisfaction note for block period AYs 2011-12 to 2017-18 failed to establish document-wise correlation with assessment years in question, lacking essential elements required under s.153C. The Tribunal quashed assessment orders made under s.153A(1)(b) and allowed assessee's appeal, finding fundamental jurisdictional defect in proceedings initiated based on inadequate satisfaction note.
ITAT invalidated assessments under s.153C read with s.153A for AYs 2011-12 and 2012-13. The AO recorded satisfaction note on 25.09.2018, making AY 2019-20 the relevant search assessment year. The years under dispute fell outside jurisdictional scope of revision proceedings. The satisfaction note for block period AYs 2011-12 to 2017-18 failed to establish document-wise correlation with assessment years in question, lacking essential elements required under s.153C. The Tribunal quashed assessment orders made under s.153A(1)(b) and allowed assessee's appeal, finding fundamental jurisdictional defect in proceedings initiated based on inadequate satisfaction note.
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TaxTMI 
TaxTMI 
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