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...
The text clarifies computation of limitation for reassessment following a search: the statutory language creates two distinct periods - a six-assessment-year window that excludes the assessment year corresponding to the previous year of the search, and a separate ten-assessment-year outer limit that is reckoned from the end of the search assessment year and therefore includes that year as the first of the ten. Applying this construction, the ten-year outer limit can render reopening for a specified assessment year time-barred; accordingly, notices issued beyond that ten-year block were held invalid in the described instance.
The text clarifies computation of limitation for reassessment following a search: the statutory language creates two distinct periods - a six-assessment-year window that excludes the assessment year corresponding to the previous year of the search, and a separate ten-assessment-year outer limit that is reckoned from the end of the search assessment year and therefore includes that year as the first of the ten. Applying this construction, the ten-year outer limit can render reopening for a specified assessment year time-barred; accordingly, notices issued beyond that ten-year block were held invalid in the described instance.
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