Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
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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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