Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
The High Court held that the notice u/s 148 of the Income Tax Act issued on April 4, 2022, was beyond the prescribed period of limitation, rendering the consequent actions illegal. Mere issuance of a notice u/s 148A for conducting an inquiry before issuing a notice u/s 148 cannot be read within the ambit of the first proviso to Section 149(1). Additionally, the notice issued on August 27, 2022, by the Joint Assessing Officer (JAO) fell outside the faceless assessment scheme u/s 151A, as it was not issued by the National Faceless Assessment Centre as required under the scheme. Consequently, the assessee's appeal was allowed.
The High Court held that the notice u/s 148 of the Income Tax Act issued on April 4, 2022, was beyond the prescribed period of limitation, rendering the consequent actions illegal. Mere issuance of a notice u/s 148A for conducting an inquiry before issuing a notice u/s 148 cannot be read within the ambit of the first proviso to Section 149(1). Additionally, the notice issued on August 27, 2022, by the Joint Assessing Officer (JAO) fell outside the faceless assessment scheme u/s 151A, as it was not issued by the National Faceless Assessment Centre as required under the scheme. Consequently, the assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
