Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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Electronic issuance of a reassessment notice occurs when it is dispatched through the ITBA system, not when digitally signed or generated. A notice recorded as issued on 1 April 2021 was therefore governed by the amended reassessment regime and required compliance with the pre-notice procedure under section 148A; its non-compliance rendered the notice invalid and vitiated the consequential reassessment order. Independently, where reassessment is initiated beyond three years from the end of the relevant assessment year, sanction must come from the specified higher authority under section 151(ii). Approval by the Principal Commissioner was incompetent, providing a separate ground to quash the notice.
Electronic issuance of a reassessment notice occurs when it is dispatched through the ITBA system, not when digitally signed or generated. A notice recorded as issued on 1 April 2021 was therefore governed by the amended reassessment regime and required compliance with the pre-notice procedure under section 148A; its non-compliance rendered the notice invalid and vitiated the consequential reassessment order. Independently, where reassessment is initiated beyond three years from the end of the relevant assessment year, sanction must come from the specified higher authority under section 151(ii). Approval by the Principal Commissioner was incompetent, providing a separate ground to quash the notice.
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