Reversal of input tax credit in proportion to exempt supply: specificity of show-cause notice required; order set aside, fresh proceedings allowed wit...
Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
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Where reassessment of a non-searched person is proposed on the basis of incriminating material seized in a search under ss. 132/132A, ss. 153A/153C, being special provisions with overriding effect, govern the field. The AO of the searched person must record a satisfaction note identifying such material as pertaining to the other person and transmit it to the jurisdictional AO; this is a statutory, jurisdictional precondition and not a procedural formality. In the absence of such satisfaction, the jurisdictional AO cannot bypass s. 153C by issuing notice under s. 148 on the same search material; s. 147/148 can be invoked only on independent, non-search material. Accordingly, the impugned s. 148 notices were quashed. - HC
Where reassessment of a non-searched person is proposed on the basis of incriminating material seized in a search under ss. 132/132A, ss. 153A/153C, being special provisions with overriding effect, govern the field. The AO of the searched person must record a satisfaction note identifying such material as pertaining to the other person and transmit it to the jurisdictional AO; this is a statutory, jurisdictional precondition and not a procedural formality. In the absence of such satisfaction, the jurisdictional AO cannot bypass s. 153C by issuing notice under s. 148 on the same search material; s. 147/148 can be invoked only on independent, non-search material. Accordingly, the impugned s. 148 notices were quashed. - HC
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