Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
Misclassification between copra and dry coconut: customs recovery and re-valuation quashed for lack of prior licensing-authority invalidation, appeals...
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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