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An unsigned notice initiating penalty proceedings under section 274 read with section 271(1)(c) was held invalid because section 282A requires statutory notices to be signed. Printing the authority's name, office, or a DIN did not satisfy that mandatory requirement, and the defect was treated as jurisdictional rather than technical. The assessee's participation and section 292B could not cure the absence of signature, and a later signed reminder notice did not validate the original initiation. As the Assessing Officer never acquired valid jurisdiction to proceed, the consequential reminder notice and penalty order were quashed.
An unsigned notice initiating penalty proceedings under section 274 read with section 271(1)(c) was held invalid because section 282A requires statutory notices to be signed. Printing the authority's name, office, or a DIN did not satisfy that mandatory requirement, and the defect was treated as jurisdictional rather than technical. The assessee's participation and section 292B could not cure the absence of signature, and a later signed reminder notice did not validate the original initiation. As the Assessing Officer never acquired valid jurisdiction to proceed, the consequential reminder notice and penalty order were quashed.
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