Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
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HC held that proceedings u/s 153C for A.Ys. 2014-15 to 2019-20 against the Petitioner are barred by limitation and therefore void. It interpreted clause (ii) of the third proviso to s.153B(1) to hold that, where the AO of the searched person and the "other person" is the same, the first limb (12 months from the end of the F.Y. of search) necessarily applies and cannot be rendered otiose. Since the search on the group of which the Petitioner is a part occurred on 21.08.2019, the basic limitation expired on 31.03.2021 and, after extension by TOLA and the relevant Notification, on 30.09.2021. As no assessment was completed by that date and the AO continued proceedings thereafter, the HC declared the assessments time-barred, quashed the s.153C proceedings, and allowed the writ petition.
HC held that proceedings u/s 153C for A.Ys. 2014-15 to 2019-20 against the Petitioner are barred by limitation and therefore void. It interpreted clause (ii) of the third proviso to s.153B(1) to hold that, where the AO of the searched person and the "other person" is the same, the first limb (12 months from the end of the F.Y. of search) necessarily applies and cannot be rendered otiose. Since the search on the group of which the Petitioner is a part occurred on 21.08.2019, the basic limitation expired on 31.03.2021 and, after extension by TOLA and the relevant Notification, on 30.09.2021. As no assessment was completed by that date and the AO continued proceedings thereafter, the HC declared the assessments time-barred, quashed the s.153C proceedings, and allowed the writ petition.
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