Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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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