COVID-19 limitation exclusion and destination-specific e-way bills govern revisional timelines and penalties for undocumented third-party plywood deli...
Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengea...
Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Reassessment notices alleging fictitious or accommodation transactions must disclose material particulars and incriminating material that prima facie link the assessee to the alleged transactions. Screenshots of Case Related Information Detail, without the underlying dissemination reports or transaction details, do not provide a meaningful statutory opportunity to respond. The Assessing Officer must independently consider the dissemination material and address objections and supporting evidence. Supplying foundational material only during writ proceedings cannot cure the defect. Failure to meet these requirements resulted in quashing of the reassessment notice, the consequential order, and the subsequent notice, without remand.
Reassessment notices alleging fictitious or accommodation transactions must disclose material particulars and incriminating material that prima facie link the assessee to the alleged transactions. Screenshots of Case Related Information Detail, without the underlying dissemination reports or transaction details, do not provide a meaningful statutory opportunity to respond. The Assessing Officer must independently consider the dissemination material and address objections and supporting evidence. Supplying foundational material only during writ proceedings cannot cure the defect. Failure to meet these requirements resulted in quashing of the reassessment notice, the consequential order, and the subsequent notice, without remand.
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