Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Validity of a scrutiny assessment depends on issuance of a valid notice under section 143(2) within the prescribed limitation period; a notice issued after that period cannot support an assessment under section 143(3). Assessment jurisdiction following transfer of proceedings also requires a valid transfer order under section 127. Statutory powers must be exercised by the authority designated by law, and failure to produce a valid transfer order leaves the officer completing the assessment without jurisdiction. These defects render the assessment void ab initio.
Validity of a scrutiny assessment depends on issuance of a valid notice under section 143(2) within the prescribed limitation period; a notice issued after that period cannot support an assessment under section 143(3). Assessment jurisdiction following transfer of proceedings also requires a valid transfer order under section 127. Statutory powers must be exercised by the authority designated by law, and failure to produce a valid transfer order leaves the officer completing the assessment without jurisdiction. These defects render the assessment void ab initio.
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