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...
Retrospective deeming of the Assessing Officer for reassessment...
Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedural.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Retrospective deeming of the Assessing Officer for reassessment under Sections 148 and 148A was treated as curing the objection based on the identity of the officer, while Section 151A was held to be only enabling and not itself a source of faceless reassessment jurisdiction. The faceless scheme notified on 29.03.2022 applied prospectively to notices under Section 148, so a notice issued earlier could not be attacked for want of faceless jurisdiction at initiation. The later substitution of Section 144B, expressly covering reassessment, was treated as clarificatory and procedural, and omission of the old sub-section 144B(9) meant procedural lapses did not automatically void the assessment. The jurisdictional challenge was rejected; the additions for unexplained investment and cash deposits were restored for fresh examination.
Retrospective deeming of the Assessing Officer for reassessment under Sections 148 and 148A was treated as curing the objection based on the identity of the officer, while Section 151A was held to be only enabling and not itself a source of faceless reassessment jurisdiction. The faceless scheme notified on 29.03.2022 applied prospectively to notices under Section 148, so a notice issued earlier could not be attacked for want of faceless jurisdiction at initiation. The later substitution of Section 144B, expressly covering reassessment, was treated as clarificatory and procedural, and omission of the old sub-section 144B(9) meant procedural lapses did not automatically void the assessment. The jurisdictional challenge was rejected; the additions for unexplained investment and cash deposits were restored for fresh examination.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
