Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
The date when the assessing officer records satisfaction upon receiving seized or re sequestered books or documents determines the 'date of search' for triggering search related assessments under the first proviso to section 153C; consequently the search year and the six preceding assessment years are fixed from that satisfaction date, not from the physical search date. Applying that principle to a satisfaction recorded on 24.05.2022 yields AY 2023 24 and preceding AYs 2017 18 to 2022 23; therefore assessments for AY 2021 22 should have proceeded by notice under the search provision rather than under section 143(2).
The date when the assessing officer records satisfaction upon receiving seized or re sequestered books or documents determines the 'date of search' for triggering search related assessments under the first proviso to section 153C; consequently the search year and the six preceding assessment years are fixed from that satisfaction date, not from the physical search date. Applying that principle to a satisfaction recorded on 24.05.2022 yields AY 2023 24 and preceding AYs 2017 18 to 2022 23; therefore assessments for AY 2021 22 should have proceeded by notice under the search provision rather than under section 143(2).
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