Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
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Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
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The ITAT affirmed the CIT(A)'s decision and dismissed all Revenue grounds, holding the impugned final assessment order vitiated. The AO's initiation under s.153C was invalid because a single consolidated satisfaction note for multiple distinct assessees and assessment years was recorded instead of distinct, year-wise satisfactions as mandated; seized material was not analyzed qua each assessment year. Applying the principle that incriminating material must be shown to pertain to a particular year, the Tribunal found non-compliance with ss.124-127 and s.153C. Further, because the assessee (a foreign non-resident and an "eligible assessee" under s.144C(15)(b)) did not receive a draft assessment as required by s.144C(1), the final order was vitiated and set aside.
The ITAT affirmed the CIT(A)'s decision and dismissed all Revenue grounds, holding the impugned final assessment order vitiated. The AO's initiation under s.153C was invalid because a single consolidated satisfaction note for multiple distinct assessees and assessment years was recorded instead of distinct, year-wise satisfactions as mandated; seized material was not analyzed qua each assessment year. Applying the principle that incriminating material must be shown to pertain to a particular year, the Tribunal found non-compliance with ss.124-127 and s.153C. Further, because the assessee (a foreign non-resident and an "eligible assessee" under s.144C(15)(b)) did not receive a draft assessment as required by s.144C(1), the final order was vitiated and set aside.
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