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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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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