Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The High Court addressed the issue of faceless assessment of income escaping assessment u/s 151A scheme. It held that notices must be issued in a faceless manner as mandated, without physical interface. The scheme allows for automated allocation and issuance of notices u/s 148 in a faceless manner. The statute aims to prevent prejudice and bias by automated allocation through risk management strategy. The Court cited judgments supporting automated issuance of notices without any interface. The Court clarified that there is no fundamental right for an assessee to demand manual issuance of notices. The Department must adhere to the scheme for assessment, re-assessment, and issuance of notices. If the Department withdraws notices, fresh notices may be issued following the scheme and u/s 151A, allowing the petitioner to respond under Section 148.
The High Court addressed the issue of faceless assessment of income escaping assessment u/s 151A scheme. It held that notices must be issued in a faceless manner as mandated, without physical interface. The scheme allows for automated allocation and issuance of notices u/s 148 in a faceless manner. The statute aims to prevent prejudice and bias by automated allocation through risk management strategy. The Court cited judgments supporting automated issuance of notices without any interface. The Court clarified that there is no fundamental right for an assessee to demand manual issuance of notices. The Department must adhere to the scheme for assessment, re-assessment, and issuance of notices. If the Department withdraws notices, fresh notices may be issued following the scheme and u/s 151A, allowing the petitioner to respond under Section 148.
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