Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
The note addresses whether documents seized from a person other than the assessee fall within the phrase 'found in the course of search' and thus may support assessment under section 153A; it records that such material (seized from an employee covered by the same search) is within that scope, but stresses that for an unabated assessment additions under 153A require incriminating material unearthed by the search. The seized document was held non incriminating, and therefore the 153A assessment based on it is invalid; a late challenge to approval and introduction of fresh appellate grounds was rejected for want of record support.
The note addresses whether documents seized from a person other than the assessee fall within the phrase 'found in the course of search' and thus may support assessment under section 153A; it records that such material (seized from an employee covered by the same search) is within that scope, but stresses that for an unabated assessment additions under 153A require incriminating material unearthed by the search. The seized document was held non incriminating, and therefore the 153A assessment based on it is invalid; a late challenge to approval and introduction of fresh appellate grounds was rejected for want of record support.
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