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...
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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.
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