Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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The court addressed whether parallel proceedings under Sections 73/74 and Section 122 (penalty) create impermissible overlap and whether the show-cause notice could proceed pending resolution of a state appeal; it declined to decide the overlap on merits but ordered the state Appellate Authority to conclude the pending appeal within a limited period - outcome: appeal to be disposed within three weeks and the Central Authorities may proceed with the show-cause notice only after that conclusion. The petitioner may thereafter file a reply raising the overlap and reliance on the CBIC circular; remedies preserved. - HC
The court addressed whether parallel proceedings under Sections 73/74 and Section 122 (penalty) create impermissible overlap and whether the show-cause notice could proceed pending resolution of a state appeal; it declined to decide the overlap on merits but ordered the state Appellate Authority to conclude the pending appeal within a limited period - outcome: appeal to be disposed within three weeks and the Central Authorities may proceed with the show-cause notice only after that conclusion. The petitioner may thereafter file a reply raising the overlap and reliance on the CBIC circular; remedies preserved. - HC
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