Just a moment...

Top
Help
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback

Contact Us At :

E-mail: [email protected]

Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters0/2000
Make Most of Text Search
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
Add to...
You have not created any category. Kindly create one to bookmark this item!
Create New Category
Hide
Title :
Description :
❮❮ Hide
Default View
Expand ❯❯
Close ✕
🔎 TMI Notes - Adv. Search
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws----
  • ---- All Laws----
  • Benami Property
  • Bill
  • Central Excise
  • Companies Law
  • Customs
  • DGFT
  • FEMA
  • GST
  • GST - States
  • IBC
  • Income Tax
  • Indian Laws
  • Money Laundering
  • SEBI
  • SEZ
  • Service Tax
  • VAT / Sales Tax
Types:
---- All Types ----
  • ---- All Types ----
  • Act Rules
  • Case Laws
  • Circulars
  • Manuals
  • News
  • Notifications
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
RelevanceDefaultDate
    A Critical Analysis of the Constitutional Validity of Section 16(4) of the CGST/BGST Act and the exp...
    Scrutiny of Procedural Flaws in GST Registration Cancellation: Insights from a High Court Judgment
    Input Tax Credit Claims under GST: A Case Study of the Kerala High Court Ruling
    Case LawsIncome Tax
    Complexities of Residential Status and Tax Liability
    Case LawsIncome Tax
    Navigating International Taxation Waters
    Resolution Applicant Eligibility in Corporate Insolvency: former director/ promotor of the corporate...
    CircularsCustoms
    Easing Export Procedures: A Detailed Analysis of India's New Customs Guidelines
    CircularsCustoms
    Streamlining Export Grievances in India: The Launch of 'e-SAMADHAAN' Portal
    CircularsCustoms
    Revamping Export Standards: India's New Directive on Quality Control for Milk and Milk Products
    Empowering Investors: SEBI's New Framework for Enhanced Trading Account Security
    Extended Validity of Pre-Shipment Inspection Agencies
    Revising Foreign Investment Norms in Alternative Investment Funds: A Critical Analysis of SEBI's Lat...
    SEBI's New Mandates for AIFs: Dematerialization of Investments and Custodian Appointment - Implicati...
    Navigating the Evolving Landscape of IT Hardware Import Regulations in India: Analyzing the DGFT Cir...
    CircularsGST - States
    GST on Imitation Zari Thread
    CircularsGST - States
    Deciphering the GST Framework: Key Clarifications on (1) Passenger Transport and Motor Vehicle Renti...
    CircularsGST - States
    Place of Supply: Key Clarifications for 3 items
    CircularsCustoms
    Regularization of Bills of Entry and Waiver of Interest in Indian Customs
    CircularsCustoms
    Enhancing Maritime Security and Transparency: The Introduction of Body-Worn Cameras for Customs Boar...
    Renewal of Recognition for AMC Repo Clearing Limited: SEBI's Decision and its Implications
❯❯
MaximizeMaximizeMaximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

    +

    Are you sure you want to delete "My most important" ?

    NOTE:

    Notes
    Showing Results for :
    Reset Filters
    Results Found:
    Show All SummariesHide All Summaries
    Case LawsGST
    Show AI Summary
    Input Tax Credit entitlement: statutory conditions and return deadlines can legitimately limit vesting of the benefit.
    The court held that Input Tax Credit is a conditional statutory benefit that vests only upon fulfilment of prescribed conditions; therefore temporal restrictions tied to return filing are legitimate legislative qualifications and do not constitute deprivation of property without authority of law or violation of equality and trade-freedom guarantees.
    Case LawsGST
    Show AI Summary
    Procedural fairness in GST registration: defective show cause notices invalidate cancellation and require fresh lawful proceedings.
    The court held the show cause notice and cancellation of GST registration were procedurally defective: the notice lacked material reasons depriving the taxpayer of an effective response, and the cancellation order demonstrated non-application of mind. Reasons contained in a reply affidavit could not retrospectively validate the defective notice. The authority may initiate fresh proceedings only by issuing a properly reasoned show cause notice, permitting the taxpayer to place all contentions and granting a personal hearing, with adjudication thereafter.
    Case LawsGST
    Show AI Summary
    Input Tax Credit eligibility: absence from GSTR 2A alone cannot bar credit; reassessment with evidentiary opportunity required
    The ruling emphasizes that Form GSTR 2A is a facilitative reconciliation tool and that denial of Input Tax Credit solely because an entry does not appear in GSTR 2A is not sufficient. The claimant bears the burden of proof to demonstrate eligibility by producing evidence of tax payment, valid invoices and transactional genuineness. The assessing authority must afford the taxpayer an opportunity to produce evidence and independently reassess the ITC claim, consistent with the self assessment framework of GST.
    Case LawsIncome Tax
    Show AI Summary
    Residential status: extended employment definition can preserve non-resident tax status for cross-border business migrants abroad.
    The tribunal addressed whether an individual who stayed 176 days in India and then moved to Mauritius on an occupation permit qualified as non-resident under Explanation 1(a) to the residence provision; after reviewing the occupation permit and appointment documentation and relying on precedent that construes "employment" to include self-employment and business activity, the tribunal found the explanatory extension applicable and excluded offshore receipts from Indian taxation.
    Case LawsIncome Tax
    Show AI Summary
    Section 172 shipping reimbursements govern TDS treatment, displacing Section 195 withholding for cross border damage payments.
    The core operative finding is that cross border payments characterised as reimbursements for vessel damage fall within the specialised shipping income regime under Section 172, so the general non resident withholding approach under Section 195 (and higher rates applied due to documentation gaps under Section 206AA) was not the appropriate mechanism; classification by legal character governs the applicable withholding treatment.
    Case LawsIBC
    Show AI Summary
    Resolution applicant eligibility: former promoters not automatically disqualified under Section 29A; clause-specific disqualifiers control.
    Whether a former promoter or director is ineligible under Section 29A turned on clause-specific disqualifiers rather than promoter status alone; the tribunal found no evidence that the statutory disqualifying conditions, including account classification as non-performing, applied to the applicant, and emphasized that eligibility requires a fact-specific application of the provision's clauses.
    CircularsCustoms
    Show AI Summary
    Back to Town export procedures revised to streamline staged re routing and ease compliance for certified exporters.
    The notice amends procedures for Back to Town (BTT) of export cargo, setting distinct workflows for self sealed cargo from CPP, port-to-CPP-to-town movements, and CFS-origin BTT. It differentiates obligations before registration, after registration but prior to LEO, and after LEO, and provides special provisions for AEO and DGFT status holders. Hazardous cargo and part cargo shut out scenarios are addressed, and the circular prescribes customs operational duties, reporting requirements, and discrepancy investigation protocols to streamline export re routing.
    CircularsCustoms
    Show AI Summary
    Export grievance redressal via e-SAMADHAAN portal provides structured online mechanism and interim replies for stakeholder issues.
    The e-SAMADHAAN portal centralises export-related grievance redressal for Jawaharlal Nehru Custom House stakeholders by providing FAQs and a mechanism to lodge grievances; NS-II (Export) will address submissions promptly and issue interim replies with timelines when external agency intervention is required. The portal is intended for public facilitation, not for legal use, and JNCH disclaims liability for use or misuse; stakeholders are encouraged to provide feedback and report implementation difficulties to the Commissioner of Customs, NS-II JNCH.
    CircularsCustoms
    Show AI Summary
    Quality control for milk exports now requires pre-export inspection and approval, aligning exports with international health standards.
    Pre-export quality control and inspection for milk and milk products are mandated under the Milk and Milk Products (Quality Control, Inspection & Monitoring) Rules, 2020. Exporters must obtain establishment approval based on a Food Safety Management System; certain consignments require consignment-wise inspection. A health certificate is required only if the importing country demands it. Customs must verify the Export Inspection Council approval or a Certificate of Inspection. Authorities are directed to sensitize officers and to align earlier orders with current international health and trade standards.
    CircularsSEBI
    Show AI Summary
    Voluntary trading account freeze empowers investors to request account blocking to prevent fraudulent trading under a regulatory framework.
    The circular requires trading members to provide a voluntary freezing/blocking facility allowing clients to request account suspension, with specified request modes, acknowledgement procedures, processing timeframes, and mechanics for implementing and lifting freezes. Stock exchanges must ensure implementation, amend rules where necessary, establish reporting requirements for trading members, and report compliance to the regulator. The measure is issued under Section 11(1) of the Securities and Exchange Board of India Act and Regulation 30 of the SEBI (Stock Brokers) Regulations to enhance investor control and prevent fraudulent trading activity.
    CircularsDGFT
    Show AI Summary
    Extension of validity of Pre-Shipment Inspection Agencies allows continued recognition under Foreign Trade Policy provisions and Handbook relaxation.
    Extension of recognition validity for Pre-Shipment Inspection Agencies under the Foreign Trade Policy 2023, relaxing Para 2.52(c) of the Handbook of Procedures and preserving recognition status for agencies listed in the policy appendices and Aayat Niryal Forms that were due to complete their three-year tenure at the end of 2023.
    CircularsSEBI
    Show AI Summary
    Foreign investment restrictions in AIFs require exclusion of sanctioned or high AML risk beneficial owners, limiting further capital contributions.
    The circular tightens investor eligibility for Alternative Investment Funds by redefining beneficial ownership thresholds and imposing disqualifications: investors or beneficial owners must not be on the United Nations Security Council Sanctions List and must not be residents of jurisdictions identified by the Financial Action Task Force as having strategic AML/CFT deficiencies. AIF managers are prohibited from accepting further capital contributions from investors who fail these conditions, with immediate effect, thereby necessitating enhanced due diligence and ongoing monitoring to ensure compliance.
    CircularsSEBI
    Show AI Summary
    Dematerialization of AIF investments required, with custodians and standardized custody reporting to enhance transparency and oversight.
    SEBI mandates dematerialization of AIF investments and the appointment of custodians, with specified conditions for associates acting as custodians, and requires standardized reporting of investments under custody to enhance transparency, reduce risks associated with physical securities, and strengthen oversight through operational and technological adjustments by AIFs and managers.
    CircularsDGFT
    Show AI Summary
    Import restrictions on specified IT hardware require valid import authorisation, while parts and certain exemptions remain available.
    The DGFT classified laptops, tablets, all in one PCs, ultra small form factor computers and servers under HSN 8471 as restricted, permitting import only against a valid Import Authorization; exclusions include desktop computers under the same chapter, spare parts and components, SEZ captive use imports, and IT hardware strictly incidental to capital goods, while importers may obtain multiple authorisations and amend quantities within value constraints.
    CircularsGST - States
    Show AI Summary
    GST rate classification on imitation zari yarn clarified to cover metallised film-based yarns while excluding refunds on specified film inputs.
    Imitation zari thread or yarn manufactured from metallised polyester film or metallised plastic film, whether used alone or blended with other fibres, is classified within the reduced GST rate category for imitation zari; however, polyester (metallised) film and plastic film inputs are not eligible for refund on account of rate inversion.
    CircularsGST - States
    Show AI Summary
    GST applicability on transport, composite supply and pure agent treatments clarified, plus job work and governmental exemptions defined.
    Services of passenger transport and renting of motor vehicles with operators where fuel is included attract GST at 5% with input tax credit within the same line of business; electricity bundled with renting or maintenance is a composite supply taxed with the principal supply while electricity supplied as a pure agent is excluded from the supplier's value; job work for processing barley into malt attracts 5% GST; exemptions for DMFTs and horticulture services/supplies to the public works department are addressed under governmental-authority exemption criteria.
    CircularsGST - States
    Show AI Summary
    Place of supply clarifications alter GST treatment for cross border transport, advertising spaces and co location services.
    Clarification sets out revised criteria for determining the place of supply for transportation of goods, advertising services involving physical spaces, and co location (server/hosting) services; the omission of a prior IGST provision requires reassessment of place of supply rules for cross border transportation, while the circular also specifies treatment for outdoor advertising and IT hosting to ensure uniform GST chargeability, invoicing and compliance across field formations.
    CircularsCustoms
    Show AI Summary
    Electronic Cash Ledger interest waiver enables regularization of manually cleared Bills of Entry after payment integration is completed.
    The notice requires stakeholders to identify unpaid challans associated with manually issued Out of Charge Bills of Entry, pay the requisite duty through the Electronic Cash Ledger within prescribed timeframes, and enable system reconciliation so that Bills of Entry are regularized. It provides for waiver and refund of interest paid, conditional on compliance with payment deadlines and successful integration of payments into the customs systems.
    CircularsCustoms
    Show AI Summary
    Body-worn cameras for customs boarding officers mandated; recording from gangway to de-boarding, with safety exceptions and pre-notice.
    Mandate requires Boarding Officers to wear a jacket bearing name and badges and a right side Body Worn Camera that records audio visual footage from approach at the gangway until de boarding; officers must notify the Shipping Agent/Line in advance, devices are standalone without wireless/SIM, and vessel Safety Officers may designate unsafe areas for non use subject to endorsement and cross verification by higher customs authorities.
    NotificationsSEBI
    Show AI Summary
    Renewal of recognition secures conditional authorisation for clearing and settlement of repo and reverse repo transactions in debt securities.
    Renewal of recognition is granted to AMC Repo Clearing Limited for a one year period, authorising it to clear and settle repo and reverse repo transactions in debt securities traded on a recognized stock exchange. The renewal is conditioned on compliance with regulatory rules and directions and restricts the Clearing Corporation to activities solely related to clearing and settlement of eligible repo and reverse repo transactions.

    TMI Notes

    Back

    All TMI Notes

    Showing Results for :
    Reset Filters
      No Records Found

      TMI Notes

      Back

      All TMI Notes

      whatsappJoin Channel
      Showing Results for : Reset Filters

      Section 153C (Finance Act, 2015) and Third-Party Search Assessments: Interplay of Belongs To and Pertains/Relates To

      28 January, 2026

      Contents
      Acts
      Plus +
      Summary
      Note

      Note

      -

      Bookmark

      Print

      Print

      This article analyses the judicial decision reproduced below, focusing on the legal reasoning adopted by the Court and its practical implications for practitioners. The judgment is analysed in the context of its factual background, issues framed, and conclusions reached by the Court.

      2023 (4) TMI 296 - Supreme Court

      At a Glance

      A dispute arose on whether the post-amendment text of Section 153C of the Income-tax Act, 1961 (as substituted by the Finance Act, 2015) can be invoked where the underlying search under Section 132 was initiated before the amendments effective date, but the satisfaction/transfer of material and issuance of notice under Section 153C occurred after that effective date.

      The court held that the amended Section 153C applies even to searches initiated before the amendments effective date. The court relied heavily on (i) the deeming fiction in the first proviso to Section 153C, and (ii) the legislative technique and legal effect of substitution, coupled with purposive construction of a machinery provision.

      For practice, the decision clarifies that the relevant legal regime for Section 153C action is not frozen on the date of search alone; where the statutory deeming fiction anchors timelines to the date of receiving seized material by the Assessing Officer having jurisdiction over the other person, the amended framework may govern subsequent Section 153C proceedings.

      Factual Background

      A search under Section 132 was conducted at the premises of a searched person/group. During the search, electronic material was seized, including data that contained references to a person other than the searched person (the other person/assessee).

      Proceedings were initiated against the other person under Section 153C. The other person objected, contending that, under the pre-amendment Section 153C, the statutory trigger required seized books/documents/assets to belong to the other person, and mere references or information relating to the other person would not satisfy the jurisdictional condition. Objections were rejected by the Assessing Officer.

      Multiple writ petitions were filed challenging notices under Section 153C (and in some cases, consequent assessment orders). The High Court quashed the Section 153C notices and consequential proceedings on the premise that the Finance Act, 2015 amendment to Section 153C could not be applied to searches initiated before the amendments effective date, treating the amendment as affecting substantive rights by expanding the class of persons covered.

      The revenue appealed, asserting that Section 153C is a machinery provision; that the amendment was by substitution and intended to remedy a restrictive interpretation of belongs to; and that, in any event, the deeming fiction in the proviso to Section 153C makes the date of receiving the seized material determinative for the other person.

      Issues Before the Court

      (1) Whether the amendment brought to Section 153C of the Income-tax Act, 1961 by the Finance Act, 2015 substituting the expression belongs or belong to with pertains or pertain to, or any information contained therein, relates to applies to Section 153C proceedings arising out of searches under Section 132 initiated prior to the amendments effective date.

      (2) Whether the High Court was correct in treating the Finance Act, 2015 amendment to Section 153C as purely prospective on the footing that it enlarges the scope of persons against whom Section 153C can be invoked, thereby affecting substantive rights.

      (3) What is the operative relevance of the first proviso to Section 153C (which deems the date of initiation of search reference, for the other person, as the date of receiving the seized material by the Assessing Officer having jurisdiction over such other person) while determining the applicable legal regime.

      Courts Reasoning

      1) Statutory architecture of Section 153C and its link to Section 153A

      Section 153C is structured as a non obstante machinery enabling assessment/reassessment of a person other than the searched person, by importing the assessment mechanism of Section 153A once specified jurisdictional conditions are met. Both the pre-amendment and post-amendment versions operate on the same core idea: where seized material connects to a non-searched person, the Assessing Officer having jurisdiction over that other person proceeds under the Section 153A framework.

      2) The critical change introduced by the Finance Act, 2015: belongs to vs pertains/relates to

      Pre-amendment Section 153C(1) required the Assessing Officer to be satisfied that books of account/documents/assets seized belongs or belong to a person other than the person referred to in Section 153A. Post-amendment Section 153C(1) retains belongs to for assets such as money, bullion, jewellery or other valuable article or thing, but, for books of account and documents, expands the trigger to where such material pertains or pertain to, or any information contained therein, relates to a person other than the searched person.

      The court treated this expansion as a legislative response to a restrictive judicial reading of belongs to, which had hindered action against third parties even where incriminating documents or information were found in the searched persons possession but did not strictly belong to the third party.

      3) Deeming fiction in the first proviso to Section 153C: date of receiving as the operative reference point

      The court placed substantial weight on the first proviso to Section 153C. Under that proviso, for the other person, the statutory reference to the date of initiation of the search under Section 132 or making of requisition under Section 132A (as appearing in the second proviso to Section 153A(1)) is to be construed as a reference to the date of receiving the seized books/documents/assets by the Assessing Officer having jurisdiction over such other person.

      This deeming rule shifts the anchor point, for the other person, away from the search initiation date and towards the date when jurisdictional material is received by the Assessing Officer of the other person. On that approach, if the receipt/transfer and the subsequent notice under Section 153C occur after the amendments effective date, the provision existing as on that date governs the proceedings.

      4) Amendment by substitution and its interpretive consequence

      The Finance Act, 2015 amendment was characterised as a substitution of text in Section 153C, not a mere addition. Relying on settled interpretive principles on substitution, the court reasoned that substitution ordinarily results in the earlier text being replaced as if the substituted text were the operative text, subject to statutory context and purpose.

      In the courts analysis, reading the amended Section 153C as inapplicable merely because the search preceded the amendment would undermine the legislative cure, given that the very mischief addressed was the inability to proceed against an other person despite incriminating material being found during search.

      5) Section 153C as a machinery provision: purposive construction to avoid frustration of the mechanism

      While acknowledging that taxing statutes are generally strictly construed, the court reiterated that machinery provisions are construed so as to make them workable and to effectuate the charge and statutory purpose. Section 153C, being the machinery for assessing any other person on the basis of search material, must be interpreted to advance its manifest purpose.

      The court reasoned that if the amended phraseology (pertains to/relates to) were denied operation for pre-amendment searches, then for a significant class of situations where incriminating information about a third party exists in seized material that does not strictly belong to that third party the Section 153C mechanism would remain ineffective, contrary to the legislative objective behind the substitution.

      6) Rejection of the substantive right/vested right objection in the given setting

      The court did not accept the contention that the amendment could not apply because it expanded coverage and affected substantive rights. It viewed Section 153C as a procedural/machinery route to assess the other person based on seized material; the issuance of notice and ensuing process does not, by itself, conclude liability. Consequently, treating the amendment as incapable of operating in such pending/future proceedings, solely due to the search being earlier, was not upheld.

      7) Procedural consequence: liberty to challenge assessments on other grounds

      Because the High Court had decided writ petitions largely on the amendment-applicability issue, other grounds to challenge notices/assessments were left undecided. The court therefore preserved the assessees liberty to pursue statutory appeals before the Commissioner of Income-tax (Appeals) on other grounds, to be considered on merits in accordance with law, subject to the stated time window (not reproduced here).

      Decision & Ratio

      The court set aside the High Courts judgment and held that the Finance Act, 2015 amendment to Section 153C applies to Section 153C proceedings even where the search under Section 132 was initiated before the amendments effective date.

      Ratio (in substance): For proceedings against an other person under Section 153C, the deeming fiction in the first proviso to Section 153C treats the relevant reference date as the date on which the Assessing Officer having jurisdiction over the other person receives the seized books/documents/assets. Where the satisfaction/receipt of material and issuance of Section 153C notice occur after the amendments effective date, the amended Section 153C widening the trigger from belongs to to pertains to/relates to for books/documents governs, and cannot be denied application solely because the search occurred earlier.

      Practical Implications

      1) Applicable law in Section 153C matters may turn on receipt/handing over rather than search initiation

      Practitioners should closely track the handover/receipt of seized material to the Assessing Officer of the other person, because the first proviso to Section 153C statutorily re-anchors the timeline for the other person to the date of receiving the material. This affects the assessment year linkage under Section 153A and, as affirmed, can also influence which version of Section 153C governs the jurisdictional trigger for documents/information.

      2) Wider evidentiary trigger post-amendment for documents and digital material

      After substitution, Section 153C(1)(b) expressly covers documents that pertain to the other person, or where any information contained therein relates to the other person. This is especially significant for electronic records and extracted datasets, where ownership/belonging may be contestable but linkage/relatability may be demonstrable.

      3) Satisfaction and bearing on determination of total income remain central

      The amended Section 153C(1) further requires that the Assessing Officer be satisfied that the seized books/documents/assets have a bearing on the determination of the other persons total income for the specified six assessment years (and the relevant years referred to in Section 153A(1)). The widened entry point does not eliminate the need for a recorded satisfaction that connects material to income determination.

      4) Writ strategy: jurisdictional challenges may not succeed solely on the pre-amendment search date

      Where the only challenge is that the search predates the amendment, the decision indicates such a challenge is unlikely to succeed if the statutory conditions (including satisfaction and receipt of material by the other persons Assessing Officer) are met post-amendment. Challenges, if any, are likely to shift toward the sufficiency of satisfaction, the nexus/bearing requirement, procedural compliance, and other statutory grounds.

      5) Appellate pathway preserved for other objections

      Even where writ petitions were disposed on the amendment point, assessees are not foreclosed from raising other grounds in statutory appeals (for example, grounds relating to the formation/recording of satisfaction, jurisdictional handover, and the nexus of seized material to income determination), subject to maintainability and limitation under the Act.

      Key Takeaways

      • Section 153C (post Finance Act, 2015) applies to proceedings against a non-searched person even if the underlying Section 132 search began before the amendments effective date.
      • The first proviso to Section 153C is pivotal: for the other person, statutory references to the search date are deemed to refer to the date of receiving seized material by the other persons Assessing Officer.
      • The substitution from belongs to to pertains to/relates to (for books of account/documents) is treated as a purposeful cure to a restrictive interpretation that hindered third-party assessments.
      • Section 153C is approached as a machinery provision; courts will prefer a construction that makes the mechanism workable and avoids frustrating legislative purpose.
      • While the amendment widens coverage, proceedings must still satisfy statutory preconditions, including satisfaction and the bearing on determination of total income requirement.

       


      Full Text:

      2023 (4) TMI 296 - Supreme Court

      Topics

      ActsIncome Tax