Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
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
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
