Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
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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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