Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
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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.
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