Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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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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