Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
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A penalty notice for undisclosed income must specify the precise statutory limb or category of penalty invoked under section 271AAB. The note explains that failure to identify the applicable charge prevents the assessee from addressing the exact allegation and undermines a reasonable opportunity of defence. It states that a notice issued under section 274 read with section 271AAB without this specification is invalid, and that a penalty founded on such defective initiation is liable to be deleted.
A penalty notice for undisclosed income must specify the precise statutory limb or category of penalty invoked under section 271AAB. The note explains that failure to identify the applicable charge prevents the assessee from addressing the exact allegation and undermines a reasonable opportunity of defence. It states that a notice issued under section 274 read with section 271AAB without this specification is invalid, and that a penalty founded on such defective initiation is liable to be deleted.
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