Tribunal confirms that notices under section 148 post-March 2022 must be issued by Faceless Assessing Officers, rendering JAO-issued notices void.
The Revenue argued that interest income from an Associated Enterprise (AE) should be taxed at the Maximum Marginal Rate MMR by invoking Article 12(6) of the DTAA} (PE exclusion). The Tribunal upheld the 15% DTAA rate, confirming that since the assessee has no PE in India, the exclusionary clause 12(6) does not apply, and the interest is a debt-claim under Article 12(4).
Discover who must file Form 1040 or 1040-SR in 2025, key deductions, and credits. Learn filing deadlines, penalties, and electronic options for accurate tax compliance.
Andhra Pradesh HC rules single GST show cause notices or assessment orders covering multiple financial years are impermissible, quashing consolidated demands.
The Court held that refund delays due to system errors cannot deny exporters interest under Section 56 of the GST Act, directing payment within 12 weeks.
Tribunal held that a reassessment notice issued beyond the surviving limitation period and without sanction from the Principal Chief Commissioner was invalid, following the Supreme Court’s rulings in Ashish Agarwal and Rajeev Bansal.
Delhi High Court quashes reassessment for AY 2016-17 in Kusum Healthcare Pvt. Ltd. vs DCIT, holding sanction by PCIT invalid under Section 151 of the Income Tax Act.
