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...
Validity of assessment u/s 153A - Non issuance of notice U/s 143(2) - Protective assessment - the assessment has been made on a protective basis, but, it is not clear whether any assessment has been framed in substantive basis in case of other/s - when the assessments in other/s assessee’s cases are not framed on substantive basis, how the protective assessment can be framed in the case of the assessee on hand. Therefore, in our considered opinion, the assessment framed on protective basis in the case of the assessee does not stand in the eyes of law. - AT
Validity of assessment u/s 153A - Non issuance of notice U/s 143(2) - Protective assessment - the assessment has been made on a protective basis, but, it is not clear whether any assessment has been framed in substantive basis in case of other/s - when the assessments in other/s assessee’s cases are not framed on substantive basis, how the protective assessment can be framed in the case of the assessee on hand. Therefore, in our considered opinion, the assessment framed on protective basis in the case of the assessee does not stand in the eyes of law. - AT
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