Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
For a search assessment of an "other person" under section 153C, the relevant date for identifying the block of assessment years is when the seized material is handed over by the searched person's Assessing Officer to the jurisdictional Assessing Officer. As the satisfaction and handing over occurred on 26.03.2019, AY 2017-18 fell within the section 153C block. The AO's resort to section 143(3) was therefore without valid jurisdiction, and the assessment for AY 2017-18 was invalid on that basis. The ITAT upheld the Commissioner (Appeals) and rejected the Revenue's challenge.
For a search assessment of an "other person" under section 153C, the relevant date for identifying the block of assessment years is when the seized material is handed over by the searched person's Assessing Officer to the jurisdictional Assessing Officer. As the satisfaction and handing over occurred on 26.03.2019, AY 2017-18 fell within the section 153C block. The AO's resort to section 143(3) was therefore without valid jurisdiction, and the assessment for AY 2017-18 was invalid on that basis. The ITAT upheld the Commissioner (Appeals) and rejected the Revenue's challenge.
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