Preliminary reassessment proceedings generally require statutory remedies unless jurisdiction is wholly absent or mandatory conditions are patently br...
Agricultural land classification requires cumulative factual indicators, while industrial-purpose land and absent agricultural use defeat reinvestment...
Composite residential flat exemption upheld where supplementary agreement merged adjoining units and additional evidence supported the taxpayer's inve...
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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.
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