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 ...
Page of 4907
Press 'Enter' after typing page number.
341 to 360 of 98136 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Section 151A and the e-Assessment of Income Escaping Assessment Scheme, 2022 require randomised automated allocation for reassessment functions, including the section 148A process and issuance of section 148 notices. General concurrent-jurisdiction directions cannot permit a jurisdictional Assessing Officer to bypass the prescribed faceless allocation, because allocation determines the officer's statutory competence. Risk-based selection of a matter is distinct from algorithmic allocation of the officer. Section 147A's retrospective deeming rule was held unconstitutional because it did not amend the continuing statutory and scheme-based requirements for automated allocation, and therefore did not remove the legal foundation of prior jurisdictional rulings. Administrative instructions cannot override the Act or a valid notified scheme.
Section 151A and the e-Assessment of Income Escaping Assessment Scheme, 2022 require randomised automated allocation for reassessment functions, including the section 148A process and issuance of section 148 notices. General concurrent-jurisdiction directions cannot permit a jurisdictional Assessing Officer to bypass the prescribed faceless allocation, because allocation determines the officer's statutory competence. Risk-based selection of a matter is distinct from algorithmic allocation of the officer. Section 147A's retrospective deeming rule was held unconstitutional because it did not amend the continuing statutory and scheme-based requirements for automated allocation, and therefore did not remove the legal foundation of prior jurisdictional rulings. Administrative instructions cannot override the Act or a valid notified scheme.
Note: It is a system-generated summary and is for quick reference only.