Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Whether a Jurisdictional Assessing Officer (JAO) can initiate proceedings under Sections 148A and 148 after implementation of the Faceless Scheme: relying on precedent that post- Faceless Scheme initiation and issuance of notices by the JAO is ultra vires and per se illegal, the court held such notices and consequential assessments unsustainable; therefore the impugned notices under Sections 148A/148 and all orders flowing therefrom are quashed. Relief is granted on jurisdictional grounds, while liberty is reserved to the revenue to pursue further action as indicated by the court. - HC
Whether a Jurisdictional Assessing Officer (JAO) can initiate proceedings under Sections 148A and 148 after implementation of the Faceless Scheme: relying on precedent that post- Faceless Scheme initiation and issuance of notices by the JAO is ultra vires and per se illegal, the court held such notices and consequential assessments unsustainable; therefore the impugned notices under Sections 148A/148 and all orders flowing therefrom are quashed. Relief is granted on jurisdictional grounds, while liberty is reserved to the revenue to pursue further action as indicated by the court. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
