Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
