Blocked input tax credit for resort construction remains unavailable; interest follows actual utilisation, while delayed payment attracts statutory pe...
Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
Jurisdictional satisfaction for penalty under section 271(1)(c) must be recorded during assessment, including a direction to initiate penalty under that provision where deemed satisfaction is invoked. Initiation under section 271AAC, a distinct provision with separate conditions and consequences, cannot support a later notice or penalty under section 271(1)(c). A subsequent penalty order cannot amend the assessment order or retrospectively create foundational jurisdiction. The penalty was therefore deleted, while the quantum appeal remained for independent determination on merits.
Jurisdictional satisfaction for penalty under section 271(1)(c) must be recorded during assessment, including a direction to initiate penalty under that provision where deemed satisfaction is invoked. Initiation under section 271AAC, a distinct provision with separate conditions and consequences, cannot support a later notice or penalty under section 271(1)(c). A subsequent penalty order cannot amend the assessment order or retrospectively create foundational jurisdiction. The penalty was therefore deleted, while the quantum appeal remained for independent determination on merits.
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