Faceless assessment and registration procedures are updated through electronic communication, revised recovery rules, extended deadlines, and replacem...
Risk-based selective vessel boarding requires accurate declarations and preserves master and agent liability where physical inspections are not select...
Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Recording reasons before issuing a reassessment notice and obtaining sanction based on independent application of mind are jurisdictional requirements. The note explains that undated recorded reasons and an undated sanction are invalid where the sanctioning authority merely writes "yes" or "approved" on a prescribed proforma without demonstrating consideration of the material. Such mechanical approval vitiates the reassessment proceedings. On these facts, the reassessment and consequential assessment order were quashed as bad in law, while other grounds became academic.
Recording reasons before issuing a reassessment notice and obtaining sanction based on independent application of mind are jurisdictional requirements. The note explains that undated recorded reasons and an undated sanction are invalid where the sanctioning authority merely writes "yes" or "approved" on a prescribed proforma without demonstrating consideration of the material. Such mechanical approval vitiates the reassessment proceedings. On these facts, the reassessment and consequential assessment order were quashed as bad in law, while other grounds became academic.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
