Limitation for consequential assessments runs from prescribed authority receipt, while verified purchases cannot be disallowed merely for unanswered s...
Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Customs valuation must use comparable contemporary imports, while confiscation fines and penalties require proportionate recalculation on reassessed v...
Depositor-protection proceedings prevail over corporate insolvency, while liquidators may recover chit receivables using copies of seized company reco...
The Supreme Court noted that conflicting High Court rulings on reassessment notices issued by the Jurisdictional Assessing Officer or through the faceless mechanism were overtaken by the Finance Act, 2021 amendments, including the retrospective insertion of section 147A and related changes to sections 147 to 151. Because the statutory basis of the impugned judgments had changed, the Court set them aside on that limited ground, remitted the matters to the High Courts for fresh consideration, and allowed the assessees to amend their writ petitions and challenge the amended provisions. All merits were left open, and further reassessment proceedings were stayed pending the writ petitions, subject to High Court orders.
The Supreme Court noted that conflicting High Court rulings on reassessment notices issued by the Jurisdictional Assessing Officer or through the faceless mechanism were overtaken by the Finance Act, 2021 amendments, including the retrospective insertion of section 147A and related changes to sections 147 to 151. Because the statutory basis of the impugned judgments had changed, the Court set them aside on that limited ground, remitted the matters to the High Courts for fresh consideration, and allowed the assessees to amend their writ petitions and challenge the amended provisions. All merits were left open, and further reassessment proceedings were stayed pending the writ petitions, subject to High Court orders.
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