Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Page of 4826
Press 'Enter' after typing page number.
6781 to 6800 of 96510 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
For assessment under s.153C, the dominant issue was whether the "date of search" for computing the ten relevant assessment years is the original search date in the searched person's case or the date on which seized material was received by the AO of the non-searched person under the first proviso to s.153C(1). Applying Explanation (1) to s.153A, the Tribunal held that the receipt date is deemed to be the search date for the non-searched person, and the ten assessment years must be counted backward from the end of the assessment year relevant to the previous year in which such deemed search occurred. Since receipt occurred in AY 2022-23, AY 2012-13 fell outside the permissible block; the Revenue's appeal failed. - ITAT
For assessment under s.153C, the dominant issue was whether the "date of search" for computing the ten relevant assessment years is the original search date in the searched person's case or the date on which seized material was received by the AO of the non-searched person under the first proviso to s.153C(1). Applying Explanation (1) to s.153A, the Tribunal held that the receipt date is deemed to be the search date for the non-searched person, and the ten assessment years must be counted backward from the end of the assessment year relevant to the previous year in which such deemed search occurred. Since receipt occurred in AY 2022-23, AY 2012-13 fell outside the permissible block; the Revenue's appeal failed. - ITAT
Note: It is a system-generated summary and is for quick reference only.