Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Under the statutory scheme for draft assessments, filing objections before the Dispute Resolution Panel requires the Faceless Assessing Officer to keep assessment proceedings in abeyance until the Panel issues directions. A final assessment cannot be made after objections have been filed and the Transfer Pricing Officer has been informed, but before those objections are decided. The final assessment order and consequential demand notice were quashed, while the pending Dispute Resolution Panel proceedings remained unaffected and may be followed by further action in accordance with law.
Under the statutory scheme for draft assessments, filing objections before the Dispute Resolution Panel requires the Faceless Assessing Officer to keep assessment proceedings in abeyance until the Panel issues directions. A final assessment cannot be made after objections have been filed and the Transfer Pricing Officer has been informed, but before those objections are decided. The final assessment order and consequential demand notice were quashed, while the pending Dispute Resolution Panel proceedings remained unaffected and may be followed by further action in accordance with law.
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