Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
The petitioner contested the levy of interest, claiming tax liability was paid from the credit ledger, precluding interest charges. However, the court observed factual issues requiring detailed scrutiny of records. The petitioner failed to annex the response to the show-cause notice, hindering the court's ability to delve into merits. The statute provides for appellate remedies, with the first appellate authority being functional, albeit the Appellate Tribunal is yet to be constituted. Considering the availability of statutory appellate mechanisms and the need for factual examination, the High Court dismissed the writ petition.
The petitioner contested the levy of interest, claiming tax liability was paid from the credit ledger, precluding interest charges. However, the court observed factual issues requiring detailed scrutiny of records. The petitioner failed to annex the response to the show-cause notice, hindering the court's ability to delve into merits. The statute provides for appellate remedies, with the first appellate authority being functional, albeit the Appellate Tribunal is yet to be constituted. Considering the availability of statutory appellate mechanisms and the need for factual examination, the High Court dismissed the writ petition.
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