Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
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Section 72(c) of the Black Money Act creates a conclusive, self-executing fiction: undeclared foreign assets acquired before the Act commenced are deemed acquired in the previous year when a Section 10 notice is issued. Assessment must follow in the immediately succeeding assessment year. Where no declaration was made, Section 72(b) does not apply. A first notice in FY 2018-19 therefore permits assessment only for AY 2019-20, rendering assessment for AY 2018-19 without jurisdiction and invalidating consequential proceedings.
Section 72(c) of the Black Money Act creates a conclusive, self-executing fiction: undeclared foreign assets acquired before the Act commenced are deemed acquired in the previous year when a Section 10 notice is issued. Assessment must follow in the immediately succeeding assessment year. Where no declaration was made, Section 72(b) does not apply. A first notice in FY 2018-19 therefore permits assessment only for AY 2019-20, rendering assessment for AY 2018-19 without jurisdiction and invalidating consequential proceedings.
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