Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
Validity of reassessment u/s. 147 - non-issuance of notice u/s. 143(2) - Onus of filing of ROI on the assessee is a responsibility which is cast upon him to be fulfilled by him, if he fails to take benefit of any of the provisions of law, the assessee cannot plea that the notice u/s. 143(2) should have been issued. In the present case, the assessee filed a letter dated 18-01-2014 requesting to treat the original return of income as in response to notice u/s. 148 of the Act. Since, the same is beyond specified time the AO cannot take cognizance of the same and proceeded with the assessment considering the notices issued u/sec. 143(2) & 142(1) of the Act on 07-08-2012. Therefore, the contention of Ld. AR that no notice u/s. 143(2) issued subsequent to the letter dated 18-01-2014 is not acceptable and rejected. - AT
Validity of reassessment u/s. 147 - non-issuance of notice u/s. 143(2) - Onus of filing of ROI on the assessee is a responsibility which is cast upon him to be fulfilled by him, if he fails to take benefit of any of the provisions of law, the assessee cannot plea that the notice u/s. 143(2) should have been issued. In the present case, the assessee filed a letter dated 18-01-2014 requesting to treat the original return of income as in response to notice u/s. 148 of the Act. Since, the same is beyond specified time the AO cannot take cognizance of the same and proceeded with the assessment considering the notices issued u/sec. 143(2) & 142(1) of the Act on 07-08-2012. Therefore, the contention of Ld. AR that no notice u/s. 143(2) issued subsequent to the letter dated 18-01-2014 is not acceptable and rejected. - AT
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