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Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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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