Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
Reopening of assessment u/s 147 - non-issue of a notice u/s 143(2) - The Circular reinforces the position that it is sine qua non for the Assessing Officer to assume jurisdiction prior to taking any steps in the matter of assessment, including reference of the matter to the TPO. The jurisdiction assumed by an officer in terms of Section 120 of the Act is activated by issuance of notice under Section 143(2), and as a consequence, failure to issue the statutory notice will lead to the inevitable result of the Officer not having assumed jurisdiction, for all practical purposes. - HC
Reopening of assessment u/s 147 - non-issue of a notice u/s 143(2) - The Circular reinforces the position that it is sine qua non for the Assessing Officer to assume jurisdiction prior to taking any steps in the matter of assessment, including reference of the matter to the TPO. The jurisdiction assumed by an officer in terms of Section 120 of the Act is activated by issuance of notice under Section 143(2), and as a consequence, failure to issue the statutory notice will lead to the inevitable result of the Officer not having assumed jurisdiction, for all practical purposes. - HC
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