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...
ITAT quashed assessment orders under Section 153C for Assessment Years 2008-09 to 2012-13, ruling the Assessing Officer lacked jurisdiction to initiate proceedings. For AY 2008-09, the satisfaction note was recorded on 23.09.2014, falling outside the statutorily permissible six-year limitation period under the second proviso to Section 153A(1). For AYs 2009-10 to 2012-13, the tribunal found fundamental jurisdictional defects: absence of proper satisfaction recording linking seized material to the assessee, no contemporaneous satisfaction by the searched person's AO, mechanical use of templated satisfaction notes across multiple years, and complete absence of incriminating material analysis. The satisfaction note failed to establish any nexus between seized diary entries and undisclosed income. Following Supreme Court precedents in Calcutta Knitwears and Jasjit Singh, the tribunal held that lacking valid jurisdictional foundation renders assessments void ab initio. Appeal allowed.
ITAT quashed assessment orders under Section 153C for Assessment Years 2008-09 to 2012-13, ruling the Assessing Officer lacked jurisdiction to initiate proceedings. For AY 2008-09, the satisfaction note was recorded on 23.09.2014, falling outside the statutorily permissible six-year limitation period under the second proviso to Section 153A(1). For AYs 2009-10 to 2012-13, the tribunal found fundamental jurisdictional defects: absence of proper satisfaction recording linking seized material to the assessee, no contemporaneous satisfaction by the searched person's AO, mechanical use of templated satisfaction notes across multiple years, and complete absence of incriminating material analysis. The satisfaction note failed to establish any nexus between seized diary entries and undisclosed income. Following Supreme Court precedents in Calcutta Knitwears and Jasjit Singh, the tribunal held that lacking valid jurisdictional foundation renders assessments void ab initio. Appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
