Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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The core issue is validity of service and jurisdiction in issuance of a Section 73 notice where no personal hearing occurred and the taxpayer failed to reply; the court held that portal upload alone, without considered attempts under Section 169(1) (eg. RPAD), may be ineffective and amounts to mere formality, so service was deficient - consequence: the impugned assessment order was without jurisdiction and set aside. The court directed that the assessment order be treated as a notice under Section 74A and the taxpayer afforded an opportunity to file a reply, thereby restoring procedural fairness. - HC
The core issue is validity of service and jurisdiction in issuance of a Section 73 notice where no personal hearing occurred and the taxpayer failed to reply; the court held that portal upload alone, without considered attempts under Section 169(1) (eg. RPAD), may be ineffective and amounts to mere formality, so service was deficient - consequence: the impugned assessment order was without jurisdiction and set aside. The court directed that the assessment order be treated as a notice under Section 74A and the taxpayer afforded an opportunity to file a reply, thereby restoring procedural fairness. - HC
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