Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
For assessments under s.153C, the block period must be computed with reference to the date on which the seized books/documents/assets are received by the jurisdictional AO of the non-searched person, and not from the date of initiation of search. This follows the statutory scheme that uses "immediately preceding" for identifying the six assessment years, while Explanation 1 to s.153A requires the extended ten-year period to be reckoned "from the end of the assessment year," i.e., from 31 March of the AY relevant to the year of search; the computation must therefore align with these distinct legislative phrases. - ITAT
For assessments under s.153C, the block period must be computed with reference to the date on which the seized books/documents/assets are received by the jurisdictional AO of the non-searched person, and not from the date of initiation of search. This follows the statutory scheme that uses "immediately preceding" for identifying the six assessment years, while Explanation 1 to s.153A requires the extended ten-year period to be reckoned "from the end of the assessment year," i.e., from 31 March of the AY relevant to the year of search; the computation must therefore align with these distinct legislative phrases. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4823 
Join Channel 
