Section 148 proceeding cannot be initiated without Addressing Objections u/s 148A(b)

Componentsource Company Ltd. Vs ACIT (Delhi High Court)

Whether a foreign company whose income is not taxable in India on account of application of DTAA can be issued notice u/s 148 for filing return of income without dealing with objections filed in response to notice u/s 148A(b)

Delhi HC held that since

at the stage of initiating action under Section 148, the respondent must be subjectively satisfied that income which was taxable has in fact escaped assessment. This aspect of criticality has clearly been ignored by the respondent while passing the impugned order. Ev

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