Classification of imported salvaged shaft pieces as ship parts confirmed, reassessment time-barred and appeal allowed restoring original classificatio...
Scope of intermediary status for data hosting services: tribunal finds provider not intermediary, services exported and not taxable, limited remand on...
CENVAT credit availability after omission of Rule 12B in textiles confirmed; late addendum to SCN introducing new grounds held time-barred and invalid...
Export of Wheat Flour and related products subject to online allocation, eligibility criteria, non-transferable six-month authorisations and reporting...
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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