Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
A writ challenge to reassessment notices on the ground that the Jurisdictional Assessing Officer lacked authority under the reassessment regime between 01.04.2021 and 01.04.2024 failed, because the retrospective insertion of Section 147A altered the foundation of contrary decisions and the jurisdictional objection no longer survived. The constitutional challenge to the amended provision was not examined in the Single Judge writ proceedings, as such a vires attack had to be pursued before the Division Bench under the High Court Writ Rules. Recovery was kept in abeyance for 30 days to permit the petitioners to seek appropriate relief before the Division Bench.
A writ challenge to reassessment notices on the ground that the Jurisdictional Assessing Officer lacked authority under the reassessment regime between 01.04.2021 and 01.04.2024 failed, because the retrospective insertion of Section 147A altered the foundation of contrary decisions and the jurisdictional objection no longer survived. The constitutional challenge to the amended provision was not examined in the Single Judge writ proceedings, as such a vires attack had to be pursued before the Division Bench under the High Court Writ Rules. Recovery was kept in abeyance for 30 days to permit the petitioners to seek appropriate relief before the Division Bench.
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