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...
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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 notices issued beyond three years require prior approval from the higher specified authority prescribed by section 151(ii); approval by a Principal Commissioner is insufficient, invalidating the notice and consequential assessment. Where an assessee asks that an original return be treated as the return filed in response to reassessment proceedings, a notice under section 143(2) becomes mandatory, and its omission invalidates the assessment. The inadequate-consideration provision for immovable property does not apply prospectively where the agreement, full payment and possession established completion of the purchase before the amendment took effect, despite later registration.
Reassessment notices issued beyond three years require prior approval from the higher specified authority prescribed by section 151(ii); approval by a Principal Commissioner is insufficient, invalidating the notice and consequential assessment. Where an assessee asks that an original return be treated as the return filed in response to reassessment proceedings, a notice under section 143(2) becomes mandatory, and its omission invalidates the assessment. The inadequate-consideration provision for immovable property does not apply prospectively where the agreement, full payment and possession established completion of the purchase before the amendment took effect, despite later registration.
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