Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
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 
