Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Section 153A creates two separate computational regimes for search-related reassessment: the six-year block uses the expression "immediately preceding" and excludes the search assessment year, while the extended ten-year block is computed "from the end of the assessment year" relevant to the previous year in which search is conducted. That wording requires inclusion of the search assessment year as the first year of the ten-year period. On that basis, Assessment Year 2014-15 fell outside the permissible ten-year limit where the search occurred in Financial Year 2023-24, and the notice under Section 148, with all consequential proceedings, was quashed as time-barred.
Section 153A creates two separate computational regimes for search-related reassessment: the six-year block uses the expression "immediately preceding" and excludes the search assessment year, while the extended ten-year block is computed "from the end of the assessment year" relevant to the previous year in which search is conducted. That wording requires inclusion of the search assessment year as the first year of the ten-year period. On that basis, Assessment Year 2014-15 fell outside the permissible ten-year limit where the search occurred in Financial Year 2023-24, and the notice under Section 148, with all consequential proceedings, was quashed as time-barred.
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