Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
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Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
The HC quashed the reassessment notice and consequential proceedings, holding that the reassessment action could not be sustained due to: (1) the alleged escaped income falling below the pecuniary threshold prescribed u/s 149(1)(b) as per the Supreme Court's ruling in Rajeev Bansal; and (2) the approval for reassessment not being granted by the competent authority u/s 151 after the introduction of the extended timelines by the Taxation Laws (Amendment) Act, 2021. The HC allowed the writ petition in favor of the assessee.
The HC quashed the reassessment notice and consequential proceedings, holding that the reassessment action could not be sustained due to: (1) the alleged escaped income falling below the pecuniary threshold prescribed u/s 149(1)(b) as per the Supreme Court's ruling in Rajeev Bansal; and (2) the approval for reassessment not being granted by the competent authority u/s 151 after the introduction of the extended timelines by the Taxation Laws (Amendment) Act, 2021. The HC allowed the writ petition in favor of the assessee.
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