Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Section 144C requires a draft assessment order before a final reassessment order imposes a prejudicial variation on a non-resident eligible assessee. Following the amendment to the definition of eligible assessee, non-residents other than companies are expressly covered. The draft procedure allows the assessee to accept the variation or seek directions from the Dispute Resolution Panel. Direct issuance of a final reassessment order without a draft order deprives the assessee of that statutory remedy. Such non-compliance is a jurisdictional defect rather than a curable procedural irregularity, rendering the final reassessment order invalid.
Section 144C requires a draft assessment order before a final reassessment order imposes a prejudicial variation on a non-resident eligible assessee. Following the amendment to the definition of eligible assessee, non-residents other than companies are expressly covered. The draft procedure allows the assessee to accept the variation or seek directions from the Dispute Resolution Panel. Direct issuance of a final reassessment order without a draft order deprives the assessee of that statutory remedy. Such non-compliance is a jurisdictional defect rather than a curable procedural irregularity, rendering the final reassessment order invalid.
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TaxTMI 
TaxTMI 
