Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Because the assessee's returned income was below the metro-city monetary threshold in CBDT Instruction No. 1/2011, the reassessment notice under section 148 had to be issued by the ITO and not the ACIT. The Tribunal held that the ACIT lacked jurisdiction under the applicable administrative instruction, so the notice was void ab initio. As the defect went to the authority issuing the notice, the consequential reassessment proceedings were also vitiated and quashed.
Because the assessee's returned income was below the metro-city monetary threshold in CBDT Instruction No. 1/2011, the reassessment notice under section 148 had to be issued by the ITO and not the ACIT. The Tribunal held that the ACIT lacked jurisdiction under the applicable administrative instruction, so the notice was void ab initio. As the defect went to the authority issuing the notice, the consequential reassessment proceedings were also vitiated and quashed.
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