Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Computation of limitation for reopening after a search must treat the six-year block and the ten-year outer limit differently: the six-year period is computed with reference to the assessment year relevant to the previous year in which the search occurred, while the ten-year outer limit is reckoned backwards from the end of that assessment year. Applying this method to a search on 04.03.2022 places AY 2013-14 as the tenth year and excludes AY 2012-13; consequently a notice issued under the reopening provision for AY 2012-13 was held time-barred and quashed.
Computation of limitation for reopening after a search must treat the six-year block and the ten-year outer limit differently: the six-year period is computed with reference to the assessment year relevant to the previous year in which the search occurred, while the ten-year outer limit is reckoned backwards from the end of that assessment year. Applying this method to a search on 04.03.2022 places AY 2013-14 as the tenth year and excludes AY 2012-13; consequently a notice issued under the reopening provision for AY 2012-13 was held time-barred and quashed.
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