Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Section 147A, enacted retrospectively to exclude faceless Assessing Officers from issuing reassessment notices, was declared unconstitutional for violating separation of powers. A validating enactment may neutralise a judicial ruling only by curing the underlying defect or removing its legal basis; Section 147A neither amended the statutory faceless reassessment scheme nor addressed its requirement of randomised automated allocation. Notices under Section 148 must be issued through faceless, randomised automated allocation under the scheme framed under Section 151A. Jurisdictional Assessing Officers therefore lacked concurrent authority to issue such notices, and notices issued outside that process were set aside.
Section 147A, enacted retrospectively to exclude faceless Assessing Officers from issuing reassessment notices, was declared unconstitutional for violating separation of powers. A validating enactment may neutralise a judicial ruling only by curing the underlying defect or removing its legal basis; Section 147A neither amended the statutory faceless reassessment scheme nor addressed its requirement of randomised automated allocation. Notices under Section 148 must be issued through faceless, randomised automated allocation under the scheme framed under Section 151A. Jurisdictional Assessing Officers therefore lacked concurrent authority to issue such notices, and notices issued outside that process were set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
