Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
Service of notice and contractual debt acknowledgment preserved insolvency admission against a corporate guarantor despite limitation and natural just...
Section 144C requires a draft assessment order before a final assessment order is made against an eligible foreign company where a prejudicial variation is proposed. The draft-order procedure enables the taxpayer to accept the variation or seek directions from the Dispute Resolution Panel before finalisation. Non-compliance is a jurisdictional defect rather than a curable procedural irregularity, and vitiates the final assessment order. Applying this principle, the assessment order was set aside for failure to issue a draft order; the taxpayer's cross-objection succeeded and the Revenue's merits appeal became infructuous.
Section 144C requires a draft assessment order before a final assessment order is made against an eligible foreign company where a prejudicial variation is proposed. The draft-order procedure enables the taxpayer to accept the variation or seek directions from the Dispute Resolution Panel before finalisation. Non-compliance is a jurisdictional defect rather than a curable procedural irregularity, and vitiates the final assessment order. Applying this principle, the assessment order was set aside for failure to issue a draft order; the taxpayer's cross-objection succeeded and the Revenue's merits appeal became infructuous.
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