Tag Archives: Joint Commissioner of Income-tax

Section 153C assessments are quashed because satisfaction notes recorded post-April 1, 2021, render proceedings non-est and time-barred. Issue Whether the assessment orders passed under Section 153C for AY 2015-16, 2016-17, and 2017-18 are legally sustainable when the mandatory satisfaction note was recorded on October 11, 2022 (Financial Year 2022-23), shifting the statutory block period and… Read More »

Valid Advance Pricing Agreements bind the Revenue, precluding alternative business expenditure disallowances under Section 37(1). Issue Whether the tax department can alternatively disallow an expenditure under Section 37(1) of the Income-tax Act after the underlying international transaction has already been covered, verified, and accepted under a binding Advance Pricing Agreement (APA) under Section 92CC. Facts… Read More »