Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
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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