Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
The HC held the issue not res integra and ruled that once the respondent-revenue issued a final assessment order followed immediately by a demand notice, it was impermissible to thereafter recharacterize that order as a draft by issuing a corrigendum; such conduct amounted to an improper circumvention of the finality of assessment. The court quashed the impugned assessment order, the accompanying demand notice and the subsequent corrigendum, restoring the petitioner's procedural rights and precluding the respondent-revenue from sustaining any second or substitute assessment predicated on the reclassification. The remedies granted were declaratory and restitutive, with the impugned instruments set aside.
The HC held the issue not res integra and ruled that once the respondent-revenue issued a final assessment order followed immediately by a demand notice, it was impermissible to thereafter recharacterize that order as a draft by issuing a corrigendum; such conduct amounted to an improper circumvention of the finality of assessment. The court quashed the impugned assessment order, the accompanying demand notice and the subsequent corrigendum, restoring the petitioner's procedural rights and precluding the respondent-revenue from sustaining any second or substitute assessment predicated on the reclassification. The remedies granted were declaratory and restitutive, with the impugned instruments set aside.
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