Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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Proceedings initiated by issuance of notice under s.153C were held not maintainable because the assessee's own premises had been searched, making him a "searched person" and not an "other person" within the scope of s.153C; consequently, the notice and consequential proceedings were quashed. Independently, the assessment order was held time-barred since, despite bearing the last permissible date and reflecting DIN generation on that date, the order did not leave the department's control and was actually booked/dispatched after the limitation date, so it could not be treated as passed within time; accordingly, the assessment order was set aside and the writ was allowed. - HC
Proceedings initiated by issuance of notice under s.153C were held not maintainable because the assessee's own premises had been searched, making him a "searched person" and not an "other person" within the scope of s.153C; consequently, the notice and consequential proceedings were quashed. Independently, the assessment order was held time-barred since, despite bearing the last permissible date and reflecting DIN generation on that date, the order did not leave the department's control and was actually booked/dispatched after the limitation date, so it could not be treated as passed within time; accordingly, the assessment order was set aside and the writ was allowed. - HC
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