Concurrent anticipatory-bail jurisdiction permits applications before either forum, while secured evidence may negate custodial interrogation in GST e...
Transfer Pricing Officer jurisdiction is transaction-specific, excluding permanent establishment determinations and requiring independent assessment o...
Clean-slate protection applies where a corporate debtor is sold as a going concern in liquidation: past liabilities and related investigations are extinguished, preventing an alleged past interest cessation from being imposed on the purchaser. Reassessment cannot rest on a presumption that unpaid interest was deducted when accounts and the taxpayer's reply showed otherwise. The same alleged cessation from one transaction cannot be taxed repeatedly across assessment years. Failure to address the clean-slate defence and binding precedents rendered the reassessment notice and section 148A(3) order for AY 2021-22 unsustainable and quashed.
Clean-slate protection applies where a corporate debtor is sold as a going concern in liquidation: past liabilities and related investigations are extinguished, preventing an alleged past interest cessation from being imposed on the purchaser. Reassessment cannot rest on a presumption that unpaid interest was deducted when accounts and the taxpayer's reply showed otherwise. The same alleged cessation from one transaction cannot be taxed repeatedly across assessment years. Failure to address the clean-slate defence and binding precedents rendered the reassessment notice and section 148A(3) order for AY 2021-22 unsustainable and quashed.
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