Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
The High Court ruled that the Joint Assistant Commissioner (JAO) lacked jurisdiction to issue notices u/s 148 for reassessment of income escaping assessment. The notices were deemed illegal and invalid due to non-compliance with Section 151A, which mandates such notices to be issued by the Faceless Assessment Officer (FAO) as per the Central Government's notification dated March 29, 2022. The Court concurred with its previous decision in Hexaware Technologies Ltd., acknowledging the JAO's lack of authority in issuing the impugned notices. Consequently, the petition was allowed in favor of the assessee, nullifying the notices issued by the JAO.
The High Court ruled that the Joint Assistant Commissioner (JAO) lacked jurisdiction to issue notices u/s 148 for reassessment of income escaping assessment. The notices were deemed illegal and invalid due to non-compliance with Section 151A, which mandates such notices to be issued by the Faceless Assessment Officer (FAO) as per the Central Government's notification dated March 29, 2022. The Court concurred with its previous decision in Hexaware Technologies Ltd., acknowledging the JAO's lack of authority in issuing the impugned notices. Consequently, the petition was allowed in favor of the assessee, nullifying the notices issued by the JAO.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4788
Join Channel
TaxTMI 
