Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Priority under section 26E of the Securitisation Act favours a bank's registered security interest over an Income Tax attachment where the Department has not publicly proclaimed the attachment in the prescribed manner or registered its claim or attachment order with CERSAI. A prior attachment alone does not displace the secured creditor's statutory priority. The attachment and resulting encumbrance must be removed to the extent they obstruct recovery of the bank's secured dues, while the Income Tax Department may recover its dues from surplus sale proceeds or other assets in accordance with law.
Priority under section 26E of the Securitisation Act favours a bank's registered security interest over an Income Tax attachment where the Department has not publicly proclaimed the attachment in the prescribed manner or registered its claim or attachment order with CERSAI. A prior attachment alone does not displace the secured creditor's statutory priority. The attachment and resulting encumbrance must be removed to the extent they obstruct recovery of the bank's secured dues, while the Income Tax Department may recover its dues from surplus sale proceeds or other assets in accordance with law.
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