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...
Faceless reassessment under the e-Assessment of Income Escaping Assessment Scheme, 2022 requires automated allocation for notices and all connected reassessment proceedings. Pre-notice enquiry and orders are inseparable from notice issuance and reassessment; concurrent-jurisdiction notifications cannot preserve a Jurisdictional Assessing Officer's authority where automated allocation was not used. Proceedings initiated under sections 148A and 148 by such officers were therefore set aside. Retrospective validating legislation must cure the statutory defect underlying prior judicial decisions and cannot merely override them; section 147A was unconstitutional because it left section 151A and the Scheme unchanged. Its insertion after repeal of the Income-tax Act, 1961 was also unsustainable, since specified commencement and saving provisions did not authorise amendment of a repealed enactment.
Faceless reassessment under the e-Assessment of Income Escaping Assessment Scheme, 2022 requires automated allocation for notices and all connected reassessment proceedings. Pre-notice enquiry and orders are inseparable from notice issuance and reassessment; concurrent-jurisdiction notifications cannot preserve a Jurisdictional Assessing Officer's authority where automated allocation was not used. Proceedings initiated under sections 148A and 148 by such officers were therefore set aside. Retrospective validating legislation must cure the statutory defect underlying prior judicial decisions and cannot merely override them; section 147A was unconstitutional because it left section 151A and the Scheme unchanged. Its insertion after repeal of the Income-tax Act, 1961 was also unsustainable, since specified commencement and saving provisions did not authorise amendment of a repealed enactment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4907 
