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 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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