PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering pr...
School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax e...
Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
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ITAT held that for a non-searched person under s.153C, the "deemed date of search" is the date on which the AO records satisfaction, not the original date of search on the searched party, following the ratio of SC in Jasjit Singh. In this case, the satisfaction note was recorded on 17.02.2022, making AY 2023-24 the relevant assessment year for reckoning the six/ten-year block. Consequently, AYs 2011-12 and 2012-13 fell outside the permissible block period. ITAT upheld the CIT(A)'s decision, holding that the AO lacked valid jurisdiction and quashing the assessments for AYs 2011-12 and 2012-13 as time-barred and invalid.
ITAT held that for a non-searched person under s.153C, the "deemed date of search" is the date on which the AO records satisfaction, not the original date of search on the searched party, following the ratio of SC in Jasjit Singh. In this case, the satisfaction note was recorded on 17.02.2022, making AY 2023-24 the relevant assessment year for reckoning the six/ten-year block. Consequently, AYs 2011-12 and 2012-13 fell outside the permissible block period. ITAT upheld the CIT(A)'s decision, holding that the AO lacked valid jurisdiction and quashing the assessments for AYs 2011-12 and 2012-13 as time-barred and invalid.
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