Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
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Section 153C proceedings were held time-barred because the satisfaction note relating to the searched person had not been recorded immediately after completion of that person's assessment. Applying Calcutta Knitwears, the Court held that "immediately" means at once after completion of the searched person's assessment, not merely within a reasonable time, and that the relevant delay is measured from that completion date. A delay of about 21 months was found incapable of satisfying the statutory requirement. The notices issued under section 153C, together with the consequential notices and orders, were quashed as unsustainable in law.
Section 153C proceedings were held time-barred because the satisfaction note relating to the searched person had not been recorded immediately after completion of that person's assessment. Applying Calcutta Knitwears, the Court held that "immediately" means at once after completion of the searched person's assessment, not merely within a reasonable time, and that the relevant delay is measured from that completion date. A delay of about 21 months was found incapable of satisfying the statutory requirement. The notices issued under section 153C, together with the consequential notices and orders, were quashed as unsustainable in law.
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