Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
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.
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