Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Section 147A, enacted retrospectively to exclude faceless Assessing Officers from issuing reassessment notices, was declared unconstitutional for violating separation of powers. A validating enactment may neutralise a judicial ruling only by curing the underlying defect or removing its legal basis; Section 147A neither amended the statutory faceless reassessment scheme nor addressed its requirement of randomised automated allocation. Notices under Section 148 must be issued through faceless, randomised automated allocation under the scheme framed under Section 151A. Jurisdictional Assessing Officers therefore lacked concurrent authority to issue such notices, and notices issued outside that process were set aside.
Section 147A, enacted retrospectively to exclude faceless Assessing Officers from issuing reassessment notices, was declared unconstitutional for violating separation of powers. A validating enactment may neutralise a judicial ruling only by curing the underlying defect or removing its legal basis; Section 147A neither amended the statutory faceless reassessment scheme nor addressed its requirement of randomised automated allocation. Notices under Section 148 must be issued through faceless, randomised automated allocation under the scheme framed under Section 151A. Jurisdictional Assessing Officers therefore lacked concurrent authority to issue such notices, and notices issued outside that process were set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
