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Faceless Assessment Mechanism: Jurisdictional Limits in Income Tax Proceedings

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..... es the intricate interplay between statutory provisions and administrative mechanisms in the realm of income tax proceedings. The court's decision sheds light on the jurisdictional limitations imposed by the faceless assessment scheme, a pioneering initiative aimed at enhancing transparency and efficiency in tax assessments. Arguments Presented The primary contention raised by the revenue auth .....

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..... ch 31, 2021, and September 6, 2021, issued u/s 119 of the Act, apply exclusively to assessment orders to be passed and do not extend to proceedings u/ss 148A and 148 of the Act. The scheme notified u/s 151A , through the notification dated March 29, 2022, is not subject to the applicability of the aforementioned orders, nor does it explicitly include their applicability. Reading the applicability .....

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..... were, therefore, illegal and without jurisdiction. The court reiterated its earlier decisions in Hexaware Technologies Limited and CapitalG LP , which consistently held that proceedings u/ss 148A and 148 of the Act, even in cases involving central charges and international taxation charges, must be conducted in a faceless manner, as mandated by Sections 144B and 151A of the Act. The court rejecte .....

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..... d international taxation charges, the court has provided clarity and upheld the principles of transparency and accountability enshrined in the faceless assessment regime. Full Text : 2024 (9) TMI 219 - BOMBAY HIGH COURT - FAQ - Frequently Asked Questions, TMI Short Notes , Experts comment, opinion Tax Management India - taxmanagementindia - taxmanagement - taxmanagementindia.com - TMI - TaxTMI .....

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