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...
Composite supply of drilling services and site specific chemicals characterised as composite supply; prior advance rulings set aside, tax rate left op...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
