Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
Direct appeals to the Tribunal against an Assessing Officer's rectification order under section 154 are not maintainable where the statutory appeal to the Commissioner (Appeals) has not first been filed. The prescribed appellate sequence requires the aggrieved taxpayer to pursue the first appellate remedy before approaching the Tribunal. An erroneous reference in Form No. 36 to a Commissioner (Appeals) order does not convert the proceeding into a valid appeal against that order.
Direct appeals to the Tribunal against an Assessing Officer's rectification order under section 154 are not maintainable where the statutory appeal to the Commissioner (Appeals) has not first been filed. The prescribed appellate sequence requires the aggrieved taxpayer to pursue the first appellate remedy before approaching the Tribunal. An erroneous reference in Form No. 36 to a Commissioner (Appeals) order does not convert the proceeding into a valid appeal against that order.
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