Blocked input tax credit for resort construction remains unavailable; interest follows actual utilisation, while delayed payment attracts statutory pe...
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...
Reopening of assessment against entity ceased to exist/amalgamating entity - The court observed that the Revenue had not considered the income tax return filed by the petitioner that included the transactions of the amalgamated entities. The notice was thus issued without a proper examination of available records and without application of mind. Highlighting the legislative intent behind section 148A of the Income Tax Act, the court noted that the reassessment provisions aim to reduce frivolous litigation and ensure fair proceedings. The court criticized the mechanical issuance of the notice without proper scrutiny of the facts and records.
Reopening of assessment against entity ceased to exist/amalgamating entity - The court observed that the Revenue had not considered the income tax return filed by the petitioner that included the transactions of the amalgamated entities. The notice was thus issued without a proper examination of available records and without application of mind. Highlighting the legislative intent behind section 148A of the Income Tax Act, the court noted that the reassessment provisions aim to reduce frivolous litigation and ensure fair proceedings. The court criticized the mechanical issuance of the notice without proper scrutiny of the facts and records.
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TaxTMI 
TaxTMI 
