Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
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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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