Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
A notice of demand under Section 156 requires an existing assessment or reassessment order fixing tax or arrears; absent such an antecedent order a demand notice is ultra vires and invalid. Where an original scrutiny assessment recorded nil liability, the revenue must invoke the reassessment/reopening procedure before creating fresh tax liability; issuing a demand years later on the same material without reopening under Section 147 amounts to an impermissible change of opinion. The impugned demand was therefore beyond jurisdiction and quashed.
A notice of demand under Section 156 requires an existing assessment or reassessment order fixing tax or arrears; absent such an antecedent order a demand notice is ultra vires and invalid. Where an original scrutiny assessment recorded nil liability, the revenue must invoke the reassessment/reopening procedure before creating fresh tax liability; issuing a demand years later on the same material without reopening under Section 147 amounts to an impermissible change of opinion. The impugned demand was therefore beyond jurisdiction and quashed.
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