Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Faceless reassessment under section 147 read with section 144B was treated as a best judgment reassessment where the assessee did not comply with section 142(1) notices and did not properly respond to section 144 show-cause notices. On that footing, the proviso to section 251(1)(a), effective from 01.10.2024, permitted the appellate authority to set aside the assessment and remand it for fresh adjudication. The remand was upheld because the assessing officer had not verified the material and additional evidence had been filed in appeal, making de novo assessment with opportunity to the assessee justified. The Revenue's objection was rejected and the reassessment was sent back for fresh disposal.
Faceless reassessment under section 147 read with section 144B was treated as a best judgment reassessment where the assessee did not comply with section 142(1) notices and did not properly respond to section 144 show-cause notices. On that footing, the proviso to section 251(1)(a), effective from 01.10.2024, permitted the appellate authority to set aside the assessment and remand it for fresh adjudication. The remand was upheld because the assessing officer had not verified the material and additional evidence had been filed in appeal, making de novo assessment with opportunity to the assessee justified. The Revenue's objection was rejected and the reassessment was sent back for fresh disposal.
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