Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
The article explains that the Finance Act 2020 amendment (effective 01.04.2020) expanded the definition of "eligible assessee" in Section 144C(15)(b) to include non-resident individuals, so the petitioner (an NRI) qualified as an eligible assessee at the time of the Section 148 notice; proceedings before the Dispute Resolution Panel under Section 144C extended limitation via Section 153, and the petitioner's post hoc Section 154 rectification was treated as an afterthought. The court found estoppel by the petitioner's conduct (including filing objections) and refused the challenge to jurisdiction absent a Transfer Order under Section 127, dismissing the writ petition.
The article explains that the Finance Act 2020 amendment (effective 01.04.2020) expanded the definition of "eligible assessee" in Section 144C(15)(b) to include non-resident individuals, so the petitioner (an NRI) qualified as an eligible assessee at the time of the Section 148 notice; proceedings before the Dispute Resolution Panel under Section 144C extended limitation via Section 153, and the petitioner's post hoc Section 154 rectification was treated as an afterthought. The court found estoppel by the petitioner's conduct (including filing objections) and refused the challenge to jurisdiction absent a Transfer Order under Section 127, dismissing the writ petition.
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