Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
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Method of communication of notice - The High Court examined the provisions of Section 282(1) of the Income Tax Act, 1961 and Rule 127(1) of the Income Tax Rules, 1962 regarding the method and manner of service of notice. - The Court concluded that communication of notice electronically should adhere strictly to the prescribed methods and does not include presumptive notification by placing it on the e-portal. - The Court ruled in favor of the petitioner, stating that they were not given a fair opportunity to respond to the proceedings under Section 12A(1)(ac)(iii) of the Act of 1961.
Method of communication of notice - The High Court examined the provisions of Section 282(1) of the Income Tax Act, 1961 and Rule 127(1) of the Income Tax Rules, 1962 regarding the method and manner of service of notice. - The Court concluded that communication of notice electronically should adhere strictly to the prescribed methods and does not include presumptive notification by placing it on the e-portal. - The Court ruled in favor of the petitioner, stating that they were not given a fair opportunity to respond to the proceedings under Section 12A(1)(ac)(iii) of the Act of 1961.
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