Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
ITAT held that notices issued under section 148 and section 148A(b) by the jurisdictional assessing officer, instead of the faceless assessing officer, are invalid and set aside; consequent reassessment orders premised on such notices are quashed. The Tribunal further determined that where the assessing officer, in reassessment proceedings, made no addition on the very issue forming the basis for reopening, the officer lacked jurisdiction to make other additions, rendering the reassessment void. Parties were granted liberty to seek revival of the appeal should controlling decisions of higher courts on the faceless-notice issue necessitate modification of this order.
ITAT held that notices issued under section 148 and section 148A(b) by the jurisdictional assessing officer, instead of the faceless assessing officer, are invalid and set aside; consequent reassessment orders premised on such notices are quashed. The Tribunal further determined that where the assessing officer, in reassessment proceedings, made no addition on the very issue forming the basis for reopening, the officer lacked jurisdiction to make other additions, rendering the reassessment void. Parties were granted liberty to seek revival of the appeal should controlling decisions of higher courts on the faceless-notice issue necessitate modification of this order.
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