Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
Assessment under section 153C was held time-barred because, in a joint warrant situation, limitation under section 153B had to be computed with reference to the last panchanama in the assessee's own case; the later panchanama of another person could not extend time, and the assessments were quashed. Jurisdiction under section 153C also failed because the satisfaction note was generic and did not record year-wise nexus between seized material and alleged undisclosed income, making the assumption of jurisdiction invalid. The addition for alleged commission income was deleted because it rested only on uncorroborated third-party statements, with no independent incriminating material and no cross-examination opportunity.
Assessment under section 153C was held time-barred because, in a joint warrant situation, limitation under section 153B had to be computed with reference to the last panchanama in the assessee's own case; the later panchanama of another person could not extend time, and the assessments were quashed. Jurisdiction under section 153C also failed because the satisfaction note was generic and did not record year-wise nexus between seized material and alleged undisclosed income, making the assumption of jurisdiction invalid. The addition for alleged commission income was deleted because it rested only on uncorroborated third-party statements, with no independent incriminating material and no cross-examination opportunity.
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