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...
Grandfathering proviso to Section 149(1)(b) preserves pre-amendment limitation computation for searches after 31.03.2021, so the amended ten-year reopening limit does not retrospectively extend time to reopen years already barred under the old regime; applying that principle the Tribunal found AY 2012-13 time barred. Section 148B is pari materia with prior law and requires prior approval founded on independent application of mind with year-wise appraisal of seized material; mechanical or omnibus approvals without examination of seized material vitiate the approval and render resultant assessments void, leading to quashing of assessments for the affected years.
Grandfathering proviso to Section 149(1)(b) preserves pre-amendment limitation computation for searches after 31.03.2021, so the amended ten-year reopening limit does not retrospectively extend time to reopen years already barred under the old regime; applying that principle the Tribunal found AY 2012-13 time barred. Section 148B is pari materia with prior law and requires prior approval founded on independent application of mind with year-wise appraisal of seized material; mechanical or omnibus approvals without examination of seized material vitiate the approval and render resultant assessments void, leading to quashing of assessments for the affected years.
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