Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Parallel reassessment proceedings under sections 147/148 did not invalidate validly initiated section 153C proceedings, because the Tribunal found no legal basis to quash section 153C merely due to non-dropping of reassessment action. However, satisfaction for invoking section 153C must be recorded without inordinate delay, and recording it nearly four years after the search was held unjustified. On that ground, the Tribunal quashed the section 153C proceedings for both assessment years, applying the same delay finding where the search date and notice date were identical.
Parallel reassessment proceedings under sections 147/148 did not invalidate validly initiated section 153C proceedings, because the Tribunal found no legal basis to quash section 153C merely due to non-dropping of reassessment action. However, satisfaction for invoking section 153C must be recorded without inordinate delay, and recording it nearly four years after the search was held unjustified. On that ground, the Tribunal quashed the section 153C proceedings for both assessment years, applying the same delay finding where the search date and notice date were identical.
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