GST payment representations require record-based, reasoned decisions while substantive entitlement remains open for determination by competent authori...
Reassessment sanction under extended limitation required approval from the competent specified authority, invalidating proceedings approved by an inco...
Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Jurisdictional objections in reassessment, including a notice issued in the name of a deceased assessee and alleged procedural non-compliance, must be addressed before merits where they could invalidate the reassessment. Section 250(6) requires the appellate authority to identify each point for determination, record its decision and provide reasons; a general reference to the assessment order does not constitute ground-wise reasoned adjudication. The authority's power to set aside a best-judgment assessment does not remove this obligation. Jurisdictional and legal grounds should be decided through a speaking order before additions are examined on merits, which arise only if the reassessment is valid.
Jurisdictional objections in reassessment, including a notice issued in the name of a deceased assessee and alleged procedural non-compliance, must be addressed before merits where they could invalidate the reassessment. Section 250(6) requires the appellate authority to identify each point for determination, record its decision and provide reasons; a general reference to the assessment order does not constitute ground-wise reasoned adjudication. The authority's power to set aside a best-judgment assessment does not remove this obligation. Jurisdictional and legal grounds should be decided through a speaking order before additions are examined on merits, which arise only if the reassessment is valid.
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