Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
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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