Reassessment for unreturned property sales survives where transfer information, non-filing, and unsupported exemption claims establish a prima facie l...
Profit-element taxation limits additions for unaccounted flat-sale receipts and grey-market purchases, while reliable search records support partial a...
Non-participating bidders cannot disturb concluded liquidation sales on speculative prejudice, while costs for such challenges must remain proportiona...
Where CBDT pecuniary-jurisdiction instructions allocate an assessee's case to an ITO, a scrutiny notice issued by an ACIT without a prior transfer order is beyond that officer's jurisdiction. An assessment founded on that notice is invalid and may be quashed without examination of the merits. The same jurisdictional principle applies where a reassessment notice is issued by an authority lacking jurisdiction over the assessee. Proper allocation and transfer of jurisdiction are therefore essential to the validity of income-tax assessment proceedings.
Where CBDT pecuniary-jurisdiction instructions allocate an assessee's case to an ITO, a scrutiny notice issued by an ACIT without a prior transfer order is beyond that officer's jurisdiction. An assessment founded on that notice is invalid and may be quashed without examination of the merits. The same jurisdictional principle applies where a reassessment notice is issued by an authority lacking jurisdiction over the assessee. Proper allocation and transfer of jurisdiction are therefore essential to the validity of income-tax assessment proceedings.
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