Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Interplay between limitation under section 144C(13) and section 153 was examined, with the tribunal considering the Madras High Court view that the two provisions are inter dependent and overlapping for matters under section 92CA; the tribunal concluded the timeline for passing final assessment orders must be determined with reference to section 144C read with section 153 and found the final assessment orders in five assessment years were passed beyond that limitation period. Outcome: the impugned final assessment orders were quashed as time barred.
Interplay between limitation under section 144C(13) and section 153 was examined, with the tribunal considering the Madras High Court view that the two provisions are inter dependent and overlapping for matters under section 92CA; the tribunal concluded the timeline for passing final assessment orders must be determined with reference to section 144C read with section 153 and found the final assessment orders in five assessment years were passed beyond that limitation period. Outcome: the impugned final assessment orders were quashed as time barred.
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