Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
The High Court held that the Assessing Officer was not justified in passing the assessment order invoking Section 144C(3) on the ground that the assessee did not file objections within the specified time u/s 144C(2)(b). The assessee had uploaded Form 35A on the Income Tax Portal and sent it physically within 30 days of receiving the draft order, fulfilling the requirement. The concept of a "draft order" was introduced with the faceless assessment scheme u/s 144B. Therefore, the assessment order and the DRP's order refraining from variations were contrary to Section 144C and liable to be quashed. Consequently, the provisional attachment u/s 281B also did not survive as it had already lived its life of 6 years without extension by the Assessing Officer after passing the assessment order.
The High Court held that the Assessing Officer was not justified in passing the assessment order invoking Section 144C(3) on the ground that the assessee did not file objections within the specified time u/s 144C(2)(b). The assessee had uploaded Form 35A on the Income Tax Portal and sent it physically within 30 days of receiving the draft order, fulfilling the requirement. The concept of a "draft order" was introduced with the faceless assessment scheme u/s 144B. Therefore, the assessment order and the DRP's order refraining from variations were contrary to Section 144C and liable to be quashed. Consequently, the provisional attachment u/s 281B also did not survive as it had already lived its life of 6 years without extension by the Assessing Officer after passing the assessment order.
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