Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Limitation for passing a final assessment under section 144C(13) must be assessed in light of the interplay between section 144C and section 153: the tribunal applied preceding decisions holding the two provisions to be mutually inclusive and overlapping, so the limitation period for a 144C(13) assessment is to be governed with reference to section 153 read with section 144C. Applying that principle, the impugned final assessment under section 143(3) read with 144C(13) was held timebarred and quashed. Parties are granted liberty to revive the appeal on merits if the pending Supreme Court larger bench decision requires modification.
Limitation for passing a final assessment under section 144C(13) must be assessed in light of the interplay between section 144C and section 153: the tribunal applied preceding decisions holding the two provisions to be mutually inclusive and overlapping, so the limitation period for a 144C(13) assessment is to be governed with reference to section 153 read with section 144C. Applying that principle, the impugned final assessment under section 143(3) read with 144C(13) was held timebarred and quashed. Parties are granted liberty to revive the appeal on merits if the pending Supreme Court larger bench decision requires modification.
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