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Absence of a signature on sanction under the reassessment provisions was treated as a challenge requiring reconsideration after the retrospective insertion of Section 292BC introduced a new legal dimension. Because the assessee had not been given an opportunity in the writ proceedings to address the effect of that retrospective provision, the court restored the writ petition for fresh consideration and left all contentions open. No opinion was expressed on the merits of the reassessment challenge, and the matter was remitted so both sides could address the applicability of the new provision before a final decision.
Absence of a signature on sanction under the reassessment provisions was treated as a challenge requiring reconsideration after the retrospective insertion of Section 292BC introduced a new legal dimension. Because the assessee had not been given an opportunity in the writ proceedings to address the effect of that retrospective provision, the court restored the writ petition for fresh consideration and left all contentions open. No opinion was expressed on the merits of the reassessment challenge, and the matter was remitted so both sides could address the applicability of the new provision before a final decision.
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