Approved gratuity fund provisions remain deductible despite general actual-payment requirements, preventing revision of the allowed gratuity deduction...
Verification of intangible software expenditure and duplicated disallowances requires record-based reassessment before depreciation and income computa...
Cash receipt aggregation requires a single transaction, event or occasion; separate partner capital contributions cannot attract cash-receipt penaltie...
Statute prescribes distinct computation for the six-year and ten-year limitation periods for reopening assessments under the search provisions; the six-year window is counted from the preceding year while the ten-year period is reckoned from the end of the assessment year relating to the previous year in which the search occurred, and therefore the ten-year span runs later than the six-year span. Applying that computation to a search dated 09.05.2024 yields AY 2025-26 as the first year and AY 2016-17 as the tenth year, rendering AY 2015-16 beyond the ten-year period and the notice to reopen that year untenable and quashed.
Statute prescribes distinct computation for the six-year and ten-year limitation periods for reopening assessments under the search provisions; the six-year window is counted from the preceding year while the ten-year period is reckoned from the end of the assessment year relating to the previous year in which the search occurred, and therefore the ten-year span runs later than the six-year span. Applying that computation to a search dated 09.05.2024 yields AY 2025-26 as the first year and AY 2016-17 as the tenth year, rendering AY 2015-16 beyond the ten-year period and the notice to reopen that year untenable and quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4925 
