Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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The HC held that the final assessment order passed under section 144B is invalid due to non-service of the mandatory Show Cause Notice proposing variation to the returned income. The Respondents admitted the Show Cause Notice was sent to an incorrect email ID not provided by the Petitioner, resulting in failure of proper service. Consequently, the impugned assessment order dated 10.03.2024 was quashed and set aside. The matter was remanded to the NFAC at the stage of issuing the Show Cause Notice, directing the Respondents to provide the Petitioner with a proper link to upload his response. The Petitioner is entitled to file a response and be granted a personal hearing before the final assessment order is passed in compliance with section 144B within 12 weeks. The final order must be reasoned and address all submissions of the Petitioner. The writ petition was disposed accordingly.
The HC held that the final assessment order passed under section 144B is invalid due to non-service of the mandatory Show Cause Notice proposing variation to the returned income. The Respondents admitted the Show Cause Notice was sent to an incorrect email ID not provided by the Petitioner, resulting in failure of proper service. Consequently, the impugned assessment order dated 10.03.2024 was quashed and set aside. The matter was remanded to the NFAC at the stage of issuing the Show Cause Notice, directing the Respondents to provide the Petitioner with a proper link to upload his response. The Petitioner is entitled to file a response and be granted a personal hearing before the final assessment order is passed in compliance with section 144B within 12 weeks. The final order must be reasoned and address all submissions of the Petitioner. The writ petition was disposed accordingly.
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