GST payment representations require record-based, reasoned decisions while substantive entitlement remains open for determination by competent authori...
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...
Reassessment litigation concerns the authority to sanction notices, the jurisdiction of a Jurisdictional Assessing Officer to issue them, and whether the prescribed faceless mechanism requires issuance by a competent Faceless Assessment Officer. The 2021 amendments to sections 147 to 151, including new section 147A, may affect pending challenges. Following remand of related matters, the petition was closed with liberty to bring a fresh challenge on the same cause, challenge section 147A, and seek consequential relief. Existing protection continues for 90 days and ceases if no fresh approach is made within that period.
Reassessment litigation concerns the authority to sanction notices, the jurisdiction of a Jurisdictional Assessing Officer to issue them, and whether the prescribed faceless mechanism requires issuance by a competent Faceless Assessment Officer. The 2021 amendments to sections 147 to 151, including new section 147A, may affect pending challenges. Following remand of related matters, the petition was closed with liberty to bring a fresh challenge on the same cause, challenge section 147A, and seek consequential relief. Existing protection continues for 90 days and ceases if no fresh approach is made within that period.
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TaxTMI 
TaxTMI 
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