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...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Electronic dispatch through the ITBA portal determines the issuance date of a reassessment notice where transmission occurs after the statutory transition to the substituted reassessment procedure. A notice dated and digitally signed before 1 April 2021 but triggered and delivered electronically on that date is treated as issued on 1 April 2021, because the Department controlled the transmission delay. Such a notice cannot proceed directly under the earlier reassessment process; it must be treated as a show-cause notice under Section 148A(b), accompanied by the relied-upon information and material, with an opportunity to object before an order under Section 148A(d). Completed reassessment proceedings and consequential notices are therefore liable to be quashed, subject to fresh proceedings and statutory defences.
Electronic dispatch through the ITBA portal determines the issuance date of a reassessment notice where transmission occurs after the statutory transition to the substituted reassessment procedure. A notice dated and digitally signed before 1 April 2021 but triggered and delivered electronically on that date is treated as issued on 1 April 2021, because the Department controlled the transmission delay. Such a notice cannot proceed directly under the earlier reassessment process; it must be treated as a show-cause notice under Section 148A(b), accompanied by the relied-upon information and material, with an opportunity to object before an order under Section 148A(d). Completed reassessment proceedings and consequential notices are therefore liable to be quashed, subject to fresh proceedings and statutory defences.
Note: It is a system-generated summary and is for quick reference only.
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