Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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The National Faceless Assessment Centre (NFAC) enhanced the book profit u/s 115JB of the Income Tax Act by Rs. 1,54,79,03,84,000 and Rs. 6,13,51,23,330 without issuing a mandatory enhancement notice u/s 251(2). The Tribunal held that without issuing the enhancement notice specifically showcasing how the assessee's income should be enhanced on particular issues, the NFAC does not have statutory power to enhance the income. Consequently, the Tribunal allowed the assessee's additional grounds and directed the deletions of the additions made to the computation of book profit u/s 115JB.
The National Faceless Assessment Centre (NFAC) enhanced the book profit u/s 115JB of the Income Tax Act by Rs. 1,54,79,03,84,000 and Rs. 6,13,51,23,330 without issuing a mandatory enhancement notice u/s 251(2). The Tribunal held that without issuing the enhancement notice specifically showcasing how the assessee's income should be enhanced on particular issues, the NFAC does not have statutory power to enhance the income. Consequently, the Tribunal allowed the assessee's additional grounds and directed the deletions of the additions made to the computation of book profit u/s 115JB.
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