Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
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 ...
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Reassessment procedure requires the Assessing Officer to furnish recorded reasons and decide objections to reopening by a speaking order before initiating scrutiny through a notice under section 143(2). A return filed in response to a reopening notice must be processed under the regular assessment procedure, but scrutiny cannot precede determination of jurisdictional objections. Further, no action, including a notice under section 142(1), may be taken for four weeks after service of an order rejecting objections. Notices issued contrary to these requirements, and consequential action, were quashed; the reopening challenge remained open.
Reassessment procedure requires the Assessing Officer to furnish recorded reasons and decide objections to reopening by a speaking order before initiating scrutiny through a notice under section 143(2). A return filed in response to a reopening notice must be processed under the regular assessment procedure, but scrutiny cannot precede determination of jurisdictional objections. Further, no action, including a notice under section 142(1), may be taken for four weeks after service of an order rejecting objections. Notices issued contrary to these requirements, and consequential action, were quashed; the reopening challenge remained open.
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