Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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...
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Faceless assessment provisions u/s 151A require notice u/s 148 for income escaping assessment to be issued by Faceless Assessing Officer (FAO), not Jurisdictional Assessing Officer (JAO). Court held JAO lacks jurisdiction to issue Section 148 notice, as it would breach Section 151A. FAO and JAO cannot have concurrent jurisdiction for issuing Section 148 notice or passing assessment/reassessment orders, as specific jurisdiction is assigned to either FAO or JAO under faceless assessment scheme, excluding the other. Allowing concurrent jurisdiction would render faceless proceedings redundant and create chaos. Since JAO admittedly lacked jurisdiction, the writ petition challenging Section 148 notice issued by JAO was allowed.
Faceless assessment provisions u/s 151A require notice u/s 148 for income escaping assessment to be issued by Faceless Assessing Officer (FAO), not Jurisdictional Assessing Officer (JAO). Court held JAO lacks jurisdiction to issue Section 148 notice, as it would breach Section 151A. FAO and JAO cannot have concurrent jurisdiction for issuing Section 148 notice or passing assessment/reassessment orders, as specific jurisdiction is assigned to either FAO or JAO under faceless assessment scheme, excluding the other. Allowing concurrent jurisdiction would render faceless proceedings redundant and create chaos. Since JAO admittedly lacked jurisdiction, the writ petition challenging Section 148 notice issued by JAO was allowed.
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