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...
Computation of the block period for assessment under search-assessment provisions was determined by the date the non-searched assessee received seized documents or, where handing-over date is unavailable, by the date of issuance of the AOs satisfaction note; consequently the relevant block period placed AY 2015-16 in the 9th year. The statutory monetary threshold for issuing notices beyond the six-year block requires escaped income represented by assets of Rs.50 lakhs or more; since AOs quantified escaped income was Rs.8,84,540 (below the threshold), the extended-year notice was invalid and appellate relief for the assessee was affirmed.
Computation of the block period for assessment under search-assessment provisions was determined by the date the non-searched assessee received seized documents or, where handing-over date is unavailable, by the date of issuance of the AOs satisfaction note; consequently the relevant block period placed AY 2015-16 in the 9th year. The statutory monetary threshold for issuing notices beyond the six-year block requires escaped income represented by assets of Rs.50 lakhs or more; since AOs quantified escaped income was Rs.8,84,540 (below the threshold), the extended-year notice was invalid and appellate relief for the assessee was affirmed.
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