Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Appointment of Registrars as adjudicating officers under Companies Act reallocates territorial jurisdiction and sets appeal route to Regional Director...
In absence of a recorded satisfaction note by Revenue, the notice date (27.05.2022) was treated as the deemed date of search for the non-searched person, fixing the deemed year of search as F.Y. 2022-23 (A.Y. 2023-24) and thus establishing the ten-year limitation block from A.Y. 2023-24 back to A.Y. 2014-15; because A.Y. 2012-13 fell outside that block the Assessing Officer lacked jurisdiction under section 153C and the assessment framed on 03.02.2023 was time-barred and was quashed, with other grounds left open.
In absence of a recorded satisfaction note by Revenue, the notice date (27.05.2022) was treated as the deemed date of search for the non-searched person, fixing the deemed year of search as F.Y. 2022-23 (A.Y. 2023-24) and thus establishing the ten-year limitation block from A.Y. 2023-24 back to A.Y. 2014-15; because A.Y. 2012-13 fell outside that block the Assessing Officer lacked jurisdiction under section 153C and the assessment framed on 03.02.2023 was time-barred and was quashed, with other grounds left open.
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