Reassessment sanction under extended limitation required approval from the competent specified authority, invalidating proceedings approved by an inco...
Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Faceless assessment procedures must provide the NFAC-prescribed minimum seven working days for a response and a meaningful opportunity of personal hearing. Allowing only one working day to reply, scheduling a hearing within less than 24 hours and before the reply deadline, and refusing a reasonable one-day adjournment denied natural justice. The assessment order, demand and penalty show-cause notices were quashed, with proceedings remanded to the show-cause-notice stage for fresh reply and hearing opportunities. Merits and other challenges remained open.
Faceless assessment procedures must provide the NFAC-prescribed minimum seven working days for a response and a meaningful opportunity of personal hearing. Allowing only one working day to reply, scheduling a hearing within less than 24 hours and before the reply deadline, and refusing a reasonable one-day adjournment denied natural justice. The assessment order, demand and penalty show-cause notices were quashed, with proceedings remanded to the show-cause-notice stage for fresh reply and hearing opportunities. Merits and other challenges remained open.
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