Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
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.