Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
The HC held that Section 153A uses two different computation methods for search assessments. For the six-year block, the phrase "immediately preceding" excludes the search assessment year; for the extended ten-year block in Explanation 1, the period is computed "from the end of" the assessment year relevant to the year of search, so the search assessment year is included as the first year. The Court rejected the Revenue's attempt to apply the six-year exclusion rule to the ten-year period. On that interpretation, Assessment Year 2015-16 was beyond the permissible ten-year span and the notice under Section 148 was quashed as time-barred.
The HC held that Section 153A uses two different computation methods for search assessments. For the six-year block, the phrase "immediately preceding" excludes the search assessment year; for the extended ten-year block in Explanation 1, the period is computed "from the end of" the assessment year relevant to the year of search, so the search assessment year is included as the first year. The Court rejected the Revenue's attempt to apply the six-year exclusion rule to the ten-year period. On that interpretation, Assessment Year 2015-16 was beyond the permissible ten-year span and the notice under Section 148 was quashed as time-barred.
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