Blocked input tax credit for resort construction remains unavailable; interest follows actual utilisation, while delayed payment attracts statutory pe...
Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
The assessee raised an issue before the CIT(Appeals) which was not adjudicated. The assessee can raise this unadjudicated issue before the Tribunal by way of an application u/r 27 of ITAT Rules, 1963, as per judicial precedents. The issue relates to the legality of the penalty notice issued u/s 274 read with Sections 270A/271AAB, without specifying the relevant limb. Since the CIT(Appeals) did not decide this legal issue, and the assessee raised it for the first time before the Tribunal, the file needs to be remanded to the CIT(Appeals) to consider the preliminary legal issue regarding the validity of penalty proceedings initiated based on the vague notice.
The assessee raised an issue before the CIT(Appeals) which was not adjudicated. The assessee can raise this unadjudicated issue before the Tribunal by way of an application u/r 27 of ITAT Rules, 1963, as per judicial precedents. The issue relates to the legality of the penalty notice issued u/s 274 read with Sections 270A/271AAB, without specifying the relevant limb. Since the CIT(Appeals) did not decide this legal issue, and the assessee raised it for the first time before the Tribunal, the file needs to be remanded to the CIT(Appeals) to consider the preliminary legal issue regarding the validity of penalty proceedings initiated based on the vague notice.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
