Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Pecuniary jurisdiction limits under the applicable CBDT instruction required reassessment of a non-corporate assessee in a mofussil area exceeding the prescribed limit to be handled by an Assistant or Deputy Commissioner, rather than an Income-tax Officer. As the reassessment notice was issued by an officer lacking that jurisdiction and the defect was unrebutted, the notice was inherently invalid. The consequential assessment was quashed as void ab initio, rendering the remaining grounds academic.
Pecuniary jurisdiction limits under the applicable CBDT instruction required reassessment of a non-corporate assessee in a mofussil area exceeding the prescribed limit to be handled by an Assistant or Deputy Commissioner, rather than an Income-tax Officer. As the reassessment notice was issued by an officer lacking that jurisdiction and the defect was unrebutted, the notice was inherently invalid. The consequential assessment was quashed as void ab initio, rendering the remaining grounds academic.
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