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Alternative statutory remedy and delay bar GST writ challenges despite pending rectification, while distinct subject matter permits parallel proceedin...
Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
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Section 153C proceedings cannot be initiated where the deemed date of search falls after 1 April 2021. Under the proviso to section 153C(1), that date is when the searched person's Assessing Officer records satisfaction and forwards seized material to the assessee's Assessing Officer. Where forwarding occurred after that date, section 153C(3) rendered the provision inapplicable, resulting in quashing of the notice and consequential assessment; other grounds became academic.
Section 153C proceedings cannot be initiated where the deemed date of search falls after 1 April 2021. Under the proviso to section 153C(1), that date is when the searched person's Assessing Officer records satisfaction and forwards seized material to the assessee's Assessing Officer. Where forwarding occurred after that date, section 153C(3) rendered the provision inapplicable, resulting in quashing of the notice and consequential assessment; other grounds became academic.
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