Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Validity of assessment proceedings under faceless assessment...
Validity of faceless assessment procedure challenged for jurisdictional AO intervention mid-remand, resulting in quashing of assessment for procedural unfairness.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Validity of assessment proceedings under faceless assessment rules is challenged where a jurisdictional assessing officer intervened during remand, causing procedural irregularity and violation of principles of natural justice; the intervention by the jurisdictional AO was unnecessary and rendered the hearing futile, and a one-day opportunity to reply was held inadequate, resulting in quashing of the impugned assessment order dated 10.12.2024. The decision underscores that remand directions must be adhered to, that change of AO mid-proceedings can vitiate the process if it breaches procedural fairness, and that adequate opportunity to be heard is mandatory.
Validity of assessment proceedings under faceless assessment rules is challenged where a jurisdictional assessing officer intervened during remand, causing procedural irregularity and violation of principles of natural justice; the intervention by the jurisdictional AO was unnecessary and rendered the hearing futile, and a one-day opportunity to reply was held inadequate, resulting in quashing of the impugned assessment order dated 10.12.2024. The decision underscores that remand directions must be adhered to, that change of AO mid-proceedings can vitiate the process if it breaches procedural fairness, and that adequate opportunity to be heard is mandatory.
Note: It is a system-generated summary and is for quick reference only.