Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
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Returns filed after the period stated in a reassessment notice are not non est where no statutory embargo applies; they must be recognised as returns in the reassessment proceedings. Once a return is on record in response to a notice under Section 142(1), issuance and service of notice under Section 143(2) are mandatory. Absence of that statutory notice creates a procedural defect that invalidates the reassessment assessment and prevents it from standing.
Returns filed after the period stated in a reassessment notice are not non est where no statutory embargo applies; they must be recognised as returns in the reassessment proceedings. Once a return is on record in response to a notice under Section 142(1), issuance and service of notice under Section 143(2) are mandatory. Absence of that statutory notice creates a procedural defect that invalidates the reassessment assessment and prevents it from standing.
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