Effective hearing in GST adjudication requires actual opportunity to respond; ineffective service through a former auditor invalidated ex parte procee...
Third-party search material requires special assessment route, rendering general reassessment notices without jurisdiction when it forms the proceedin...
Transfer-pricing adjustments must be confined to international associated-enterprise transactions, while functionally dissimilar comparables remain ex...
Insolvency moratorium bars income-tax revision proceedings against corporate debtors until the moratorium ends, preserving merits for later determinat...
Section 271AAD authorises only the Assessing Officer, Joint Commissioner (Appeals) and Commissioner (Appeals) to initiate or impose penalty for false entries in books of account; it does not confer that power on the Principal Commissioner or Commissioner. Penalty is not automatic and requires a final determination that a false entry exists. Revisionary jurisdiction cannot be used to direct the Assessing Officer to commence section 271AAD penalty proceedings while the underlying disallowance of contract expenditure remains under appellate consideration. The revisionary direction was therefore legally unsustainable and was quashed.
Section 271AAD authorises only the Assessing Officer, Joint Commissioner (Appeals) and Commissioner (Appeals) to initiate or impose penalty for false entries in books of account; it does not confer that power on the Principal Commissioner or Commissioner. Penalty is not automatic and requires a final determination that a false entry exists. Revisionary jurisdiction cannot be used to direct the Assessing Officer to commence section 271AAD penalty proceedings while the underlying disallowance of contract expenditure remains under appellate consideration. The revisionary direction was therefore legally unsustainable and was quashed.
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TaxTMI 
TaxTMI 
of 4927 
