Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
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The ITAT Delhi considered the validity of a re-assessment order where no notice u/s 148 was served on the assessee. The notice u/s 148 was issued through the ITBA portal but sent to the wrong email ID. The tribunal held that the notice generated on 30.03.2021 was not served on the assessee as the email ID did not belong to them. The limitation for issuing the notice would have ended on 30.03.2020, extended to 31.03.2021 due to Covid-19. The AO issued the notice just one day before the extended deadline, but the revenue failed to prove its service. The decision favored the assessee due to the lack of proper service of the notice.
The ITAT Delhi considered the validity of a re-assessment order where no notice u/s 148 was served on the assessee. The notice u/s 148 was issued through the ITBA portal but sent to the wrong email ID. The tribunal held that the notice generated on 30.03.2021 was not served on the assessee as the email ID did not belong to them. The limitation for issuing the notice would have ended on 30.03.2020, extended to 31.03.2021 due to Covid-19. The AO issued the notice just one day before the extended deadline, but the revenue failed to prove its service. The decision favored the assessee due to the lack of proper service of the notice.
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