Prospective valuation amendment limits reassessment: unamended fair market value reference could not justify reopening based on a registered valuer's ...
Exemption for examination-related services rejected where recipients were commercial entities; suppression sustained extended limitation and penalties...
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The High Court held that an Assessing Officer could not invoke Section 154 of the Income-tax Act, 1961 to rectify a determination made by the Principal Commissioner under Section 5(2) of the Direct Tax Vivad se Vishwas Act, 2020. The scheme itself contains no rectification power, and Section 5(3) makes the amount determined and the order passed under the scheme final and conclusive. As the Act of 2020 does not apply the rectification provisions of the Income-tax Act to such determinations, the rectification order was without authority and was quashed.
The High Court held that an Assessing Officer could not invoke Section 154 of the Income-tax Act, 1961 to rectify a determination made by the Principal Commissioner under Section 5(2) of the Direct Tax Vivad se Vishwas Act, 2020. The scheme itself contains no rectification power, and Section 5(3) makes the amount determined and the order passed under the scheme final and conclusive. As the Act of 2020 does not apply the rectification provisions of the Income-tax Act to such determinations, the rectification order was without authority and was quashed.
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