Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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Service of a reassessment notice under section 148 is a jurisdictional condition precedent for valid assumption of reassessment power. Where the revenue could not produce proof of effective delivery, including a tracking report or other evidence of service, mere generation or dispatch of the notice was held insufficient. The absence of valid service deprived the assessee of an opportunity to place material before the AO and vitiated the reassessment. The HC quashed the assessment order and remanded the matter for fresh consideration after due notice and opportunity to respond.
Service of a reassessment notice under section 148 is a jurisdictional condition precedent for valid assumption of reassessment power. Where the revenue could not produce proof of effective delivery, including a tracking report or other evidence of service, mere generation or dispatch of the notice was held insufficient. The absence of valid service deprived the assessee of an opportunity to place material before the AO and vitiated the reassessment. The HC quashed the assessment order and remanded the matter for fresh consideration after due notice and opportunity to respond.
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