Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Reassessment beyond three years under section 149(1)(b) was unavailable because the Assessing Officer did not possess material showing escapement of income represented in the form of an asset of fifty lakh rupees or more. The order under section 148A(d) was found non-speaking, as it failed to explain why the housing loan sanction letter, bank statements and other supporting documents were unacceptable; the property purchase was substantially explained by the loan, and any remaining unexplained amount stayed below the statutory threshold. The notice under section 148 was therefore barred by limitation, the reopening was treated as a roving and fishing enquiry, and the section 148A(d) order, notice under section 148, and consequential assessment under section 147 were quashed.
Reassessment beyond three years under section 149(1)(b) was unavailable because the Assessing Officer did not possess material showing escapement of income represented in the form of an asset of fifty lakh rupees or more. The order under section 148A(d) was found non-speaking, as it failed to explain why the housing loan sanction letter, bank statements and other supporting documents were unacceptable; the property purchase was substantially explained by the loan, and any remaining unexplained amount stayed below the statutory threshold. The notice under section 148 was therefore barred by limitation, the reopening was treated as a roving and fishing enquiry, and the section 148A(d) order, notice under section 148, and consequential assessment under section 147 were quashed.
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