Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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Issue of faceless assessment of income escaping assessment, where the notice u/s 148 of the Income Tax Act was issued by the Jurisdictional Assessing Officer (JAO) instead of the Faceless Assessing Officer (FAO), as required by Section 151A. The High Court held that for a valid reassessment notice u/s 148, the Revenue must comply with Section 151A, as interpreted in the cases of Hexaware Technologies Limited and Nainraj Enterprises Pvt. Ltd. The Court ruled that the JAO is not permitted to issue a notice u/s 148, as it would breach Section 151A. There is no concurrent jurisdiction between the JAO and FAO for issuing notices u/s 148 or passing assessment/reassessment orders. Accepting the Revenue's argument would lead to chaos and render faceless proceedings redundant. The decision was in favor of the assessee.
Issue of faceless assessment of income escaping assessment, where the notice u/s 148 of the Income Tax Act was issued by the Jurisdictional Assessing Officer (JAO) instead of the Faceless Assessing Officer (FAO), as required by Section 151A. The High Court held that for a valid reassessment notice u/s 148, the Revenue must comply with Section 151A, as interpreted in the cases of Hexaware Technologies Limited and Nainraj Enterprises Pvt. Ltd. The Court ruled that the JAO is not permitted to issue a notice u/s 148, as it would breach Section 151A. There is no concurrent jurisdiction between the JAO and FAO for issuing notices u/s 148 or passing assessment/reassessment orders. Accepting the Revenue's argument would lead to chaos and render faceless proceedings redundant. The decision was in favor of the assessee.
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