https://www.taxtmi.com/caselaws?id=466181 Legality of notice issued under Section 153A focuses on the scope of "relevant assessment years" as per Explanation 1; the ten-year limit was held to exclude the impugned year, rendering the 153A notice and consequent assessment void ab initio and quashed for that year. Treatment of unaccounted cash receipts from sale of spent solvents/scrap was addressed by applying prior tribunal precedents to allow 60% as expenditure and treat 40% as income; AO directed to follow this apportionment. The satisfaction note for issuance of notice under 153A was found to meet threshold facts based on income represented as assets. Deemed dividend additions were deleted and related dividend distribution tax set aside. en-us Tue, 04 Feb 2025 00:00:00 +0530 Thu, 22 Jan 2026 11:36:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466181 Legality of notice issued under Section 153A focuses on the scope of "relevant assessment years" as per Explanation 1; the ten-year limit was held to exclude the impugned year, rendering the 153A notice and consequent assessment void ab initio and quashed for that year. Treatment of unaccounted cash receipts from sale of spent solvents/scrap was addressed by applying prior tribunal precedents to allow 60% as expenditure and treat 40% as income; AO directed to follow this apportionment. The satisfaction note for issuance of notice under 153A was found to meet threshold facts based on income represented as assets. Deemed dividend additions were deleted and related dividend distribution tax set aside. Case-Laws Income Tax Tue, 04 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466181