Faceless assessment and registration procedures are updated through electronic communication, revised recovery rules, extended deadlines, and replacem...
Risk-based selective vessel boarding requires accurate declarations and preserves master and agent liability where physical inspections are not select...
Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Reopening of assessment u/s 147 - no original assessment order in the case of the assessee passed - Even assuming for the sake of argument that if an intimation under Section 143(1) of the Act is considered to be an order of assessment, in the subsequent re-assessment proceeding, the original assessment proceeding get effaced and the AO was required to consider the proceeding de novo and to consider the claim of the assessee. - HC
Reopening of assessment u/s 147 - no original assessment order in the case of the assessee passed - Even assuming for the sake of argument that if an intimation under Section 143(1) of the Act is considered to be an order of assessment, in the subsequent re-assessment proceeding, the original assessment proceeding get effaced and the AO was required to consider the proceeding de novo and to consider the claim of the assessee. - HC
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