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...
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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