Misdeclaration of quantity rejected where supplier evidence established counting errors, so reassessment, confiscation and redemption fine were set as...
Admissibility of electronic evidence controls valuation and penalty exposure; non compliant e records and statements nullify revaluation and penalties...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
