Government water works contract GST concession applied before its withdrawal, while contractual tax reimbursement claims lay outside advance-ruling sc...
Stamp valuation increases after registration-fee payment led to deletion of property-purchase addition within tolerance and without valuation referral...
The ITAT held that the notice issued under section 153C for AY 2015-16 was barred by limitation, as the limitation period must be reckoned from the date of recording the satisfaction note (10.06.2021) and not the date of search (20.07.2018). Consequently, proceedings for AY 2015-16 were without jurisdiction and liable to be quashed. Further, the tribunal found the satisfaction note to be cryptic and lacking tangible, descriptive information, failing to demonstrate proper application of mind by the AO. This legal infirmity rendered the assumption of jurisdiction under section 153C invalid. The AO's failure to specify documents or assets pertaining to each assessment year in the consolidated satisfaction note vitiated the notice and assessment order. Accordingly, the appeal was allowed, and the proceedings and assessment under section 153C were quashed as null and void.
The ITAT held that the notice issued under section 153C for AY 2015-16 was barred by limitation, as the limitation period must be reckoned from the date of recording the satisfaction note (10.06.2021) and not the date of search (20.07.2018). Consequently, proceedings for AY 2015-16 were without jurisdiction and liable to be quashed. Further, the tribunal found the satisfaction note to be cryptic and lacking tangible, descriptive information, failing to demonstrate proper application of mind by the AO. This legal infirmity rendered the assumption of jurisdiction under section 153C invalid. The AO's failure to specify documents or assets pertaining to each assessment year in the consolidated satisfaction note vitiated the notice and assessment order. Accordingly, the appeal was allowed, and the proceedings and assessment under section 153C were quashed as null and void.
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