S. 144C : Reference to dispute resolution panel-Limitation-Notice by Dispute Resolution Panel four years after direction by Tribunal-Barred by limitation-High Court has power to quash show-cause notice-Decisions of single judge affirmed. [S. 92C, 92CA, 144C(13), 153, 254 (1), Art. 226]
S. 144B : Faceless Assessment -Best judgment assessment-Reassessment-Alternative remedy High Court in writ jurisdiction cannot consider facts-Writ was dismissed.-National Faceless Assessment Scheme – Disposal of objections and framing of assessment was done by AO- only orders were conveyed by NFAC instead of AO – Claim of petitioner that NFAC was not income tax authority to exercise power of framing assessment was invalidDuty of assessee to intimate change of aaddress to Imcome -tax Autoriries [S. 139,139A(5), 144 147, 148, 282 Art. 226]
S. 144B : Faceless Assessment-Cash credits-Failure to afford requested opportunity of hearing-Assessment order quashed and matter remanded. [S. 68, 142(1), Art. 226]
S. 144A : Power-Joint Commissioner-Direction-Transfer pricing-Arm’s Length Price-Must be given opportunity to be heard-Order not valid. [S. 37, 40A(2), 92(1), 139, 142(1), Art. 226]
S. 139A : Permanent account number-Duty of assessee to intimate change of address to Income-Tax Authorities. [S. 139A(5)(d), 144, 147, 148, Art. 226]
S. 132 : Search and seizure-Non-filer of return-Satisfaction note showed that the Assessee had assets or income which would not be disclosed to Income-Tax Authorities-Search proceedings valid. [Art. 226]
S. 132 : Search and seizure-Non-filer of return-Satisfaction note showed that the Assessee had assets or income which would not be disclosed to Income-Tax Authorities-Search proceedings valid. [Art. 226]
S. 131 : Power-Discovery-Production of evidence-Survey-Impounding of documents-Retention beyond fifteen days without approval of higher Authority is not valid-Decision of approval must be communicated to the assessee. [S. 131(3), 133A]
S. 127 : Power to transfer cases-Opportunity of hearing should be provided-Reason for transfer should be recorded-Transfer of case without notice and reasons for transfer is not valid. [Art. 226]
S. 90 : Double taxation relief-Mutual agreement procedure-DTAA has precedence over provisions of Act where beneficial to assessee-Respondents are directed to take necessary measures within a reasonable time-DTAA-India-USA. [S. 90(2), IT Rule, 44F, 44G 44H, Art. 27(2)]