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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Immunity from penalty for under-reporting of income requires reconsideration where a timely Form No. 68 application is followed by rectification of the assessment demand resulting in a refund. The material states that neither the penalty order nor the appellate order considered whether the rectification affected compliance with the requirement to pay tax and interest, particularly where no demand ultimately survived. The immunity claim was restored for fresh examination by a speaking order after granting reasonable opportunity, with consequential reconsideration of the penalty issue if required.
Immunity from penalty for under-reporting of income requires reconsideration where a timely Form No. 68 application is followed by rectification of the assessment demand resulting in a refund. The material states that neither the penalty order nor the appellate order considered whether the rectification affected compliance with the requirement to pay tax and interest, particularly where no demand ultimately survived. The immunity claim was restored for fresh examination by a speaking order after granting reasonable opportunity, with consequential reconsideration of the penalty issue if required.
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