Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The article addresses the requirement that assumption of jurisdiction under section 153C requires a contemporaneous, written and year specific satisfaction by the Assessing Officer linking seized material to each assessment year; consolidated or blanket satisfaction spanning multiple years without year wise nexus is legally insufficient. Applying this principle, assessments founded on such undifferentiated satisfaction notes are unsustainable and liable to be quashed as void ab initio where no year specific incriminating material is shown to relate to the assessee for the years under consideration.
The article addresses the requirement that assumption of jurisdiction under section 153C requires a contemporaneous, written and year specific satisfaction by the Assessing Officer linking seized material to each assessment year; consolidated or blanket satisfaction spanning multiple years without year wise nexus is legally insufficient. Applying this principle, assessments founded on such undifferentiated satisfaction notes are unsustainable and liable to be quashed as void ab initio where no year specific incriminating material is shown to relate to the assessee for the years under consideration.
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