Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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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