Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
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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.
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