Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Faceless reassessment under the IT Act was challenged on the ground that the notice under section 148 had to be issued by the Faceless Assessing Officer and not the jurisdictional officer for alleged non-compliance with section 151A. Without deciding that merits question, the Court directed revival of the pending appeal before the Commissioner (Appeals), permitted the petitioner to raise all grounds including limitation, stayed operation of the assessment order during the appeal, and ordered expeditious disposal.
Faceless reassessment under the IT Act was challenged on the ground that the notice under section 148 had to be issued by the Faceless Assessing Officer and not the jurisdictional officer for alleged non-compliance with section 151A. Without deciding that merits question, the Court directed revival of the pending appeal before the Commissioner (Appeals), permitted the petitioner to raise all grounds including limitation, stayed operation of the assessment order during the appeal, and ordered expeditious disposal.
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