Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Reassessment notices must be initiated through the faceless assessment framework rather than by the Jurisdictional Assessing Officer where algorithm-based random allocation governs reassessment proceedings. A final assessment order issued under the faceless regime does not cure the initial jurisdictional defect. Where the final order is already challenged before the Commissioner of Income Tax (Appeals), the jurisdictional objection should be raised and considered in that statutory appeal, applying the relevant High Court precedents. The assessment order need not be independently quashed in writ proceedings when the pending appeal can address the objection.
Reassessment notices must be initiated through the faceless assessment framework rather than by the Jurisdictional Assessing Officer where algorithm-based random allocation governs reassessment proceedings. A final assessment order issued under the faceless regime does not cure the initial jurisdictional defect. Where the final order is already challenged before the Commissioner of Income Tax (Appeals), the jurisdictional objection should be raised and considered in that statutory appeal, applying the relevant High Court precedents. The assessment order need not be independently quashed in writ proceedings when the pending appeal can address the objection.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
