Loading...

⚠ ✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
TMI Blog
Home / TMI Blogs / RSS

Automated allocation governs reassessment notices, while retrospective validation cannot override unamended faceless jurisdictional requirements under the statutory scheme.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....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.....