Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
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.
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