Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
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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
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