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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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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