Customs valuation must use comparable contemporary imports, while confiscation fines and penalties require proportionate recalculation on reassessed v...
Depositor-protection proceedings prevail over corporate insolvency, while liquidators may recover chit receivables using copies of seized company reco...
Intermediary service classification fails where overseas admission facilitation is supplied independently, preserving export treatment and small-provi...
Satellite transponder bandwidth is telecommunication, not Business Support Service; foreign non-telegraph providers triggered no service tax liability...
Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
For search-related reassessment, the HC held that the six-year block under section 153A and the extended ten-year block under Explanation 1 use different computation methods, and the language of the ten-year provision requires the search assessment year to be included as the first year in the reckoning. On that construction, a search conducted in FY 2023-24 made AY 2024-25 the first year and AY 2015-16 the tenth year, so AY 2014-15 fell outside the permissible period. The Court followed its earlier view and rejected the Revenue's contrary interpretation, quashing the section 148 notice for AY 2014-15 as time-barred.
For search-related reassessment, the HC held that the six-year block under section 153A and the extended ten-year block under Explanation 1 use different computation methods, and the language of the ten-year provision requires the search assessment year to be included as the first year in the reckoning. On that construction, a search conducted in FY 2023-24 made AY 2024-25 the first year and AY 2015-16 the tenth year, so AY 2014-15 fell outside the permissible period. The Court followed its earlier view and rejected the Revenue's contrary interpretation, quashing the section 148 notice for AY 2014-15 as time-barred.
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