Proportionate interest, unexplained credits and partner remuneration disputed; proofs of fund nexus and lender identity were decisive and disallowance...
Capital gains valuation from stamp assessment versus net consideration for residential reinvestment: deemed stamp value replaced for gains but not for...
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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