Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
HC quashed the reopening and consequential proceedings in favour of the assessee. The court found the notice issued under s.148A(b) for AY 2014-15 impermissibly relied on the return and assessment materials of a different year (AY 2013-14), so the Revenue lacked foundational information to form reasons to believe for reopening under s.147. Further, the jurisdictional officer initiated proceedings beyond the limitation prescribed by amended s.149 (effective 01.04.2021), and the show-cause notice dated 23.05.2022 did not disclose information pertinent to AY 2014-15. For these reasons the HC held the impugned notice and proceedings void and quashed them.
HC quashed the reopening and consequential proceedings in favour of the assessee. The court found the notice issued under s.148A(b) for AY 2014-15 impermissibly relied on the return and assessment materials of a different year (AY 2013-14), so the Revenue lacked foundational information to form reasons to believe for reopening under s.147. Further, the jurisdictional officer initiated proceedings beyond the limitation prescribed by amended s.149 (effective 01.04.2021), and the show-cause notice dated 23.05.2022 did not disclose information pertinent to AY 2014-15. For these reasons the HC held the impugned notice and proceedings void and quashed them.
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