Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
Recording of a satisfaction note by the assessing officer of the searched person is a jurisdictional prerequisite to initiate proceedings and frame assessment in respect of a non-searched person under section 153C; absence of that satisfaction note vitiates jurisdiction and merits quashing of the assessment. Where limitation for an assessment year is to be computed, the relevant date is the date of satisfaction/handing over of records; applying that date, the Tribunal found the assessment year barred by limitation and quashed the assessment. The Tribunal therefore dismissed the Revenue's appeal and upheld quashing of the assessment.
Recording of a satisfaction note by the assessing officer of the searched person is a jurisdictional prerequisite to initiate proceedings and frame assessment in respect of a non-searched person under section 153C; absence of that satisfaction note vitiates jurisdiction and merits quashing of the assessment. Where limitation for an assessment year is to be computed, the relevant date is the date of satisfaction/handing over of records; applying that date, the Tribunal found the assessment year barred by limitation and quashed the assessment. The Tribunal therefore dismissed the Revenue's appeal and upheld quashing of the assessment.
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