Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Reassessment completed under section 147 read with section 143(3) without issuance of mandatory notice under section 143(2) was held void by the ITAT. The record, including RTI material, did not show issuance of notice, and section 292BB was held to cure only defects in service, not the complete absence of notice. As the reassessment was a nullity, the consequential revision under section 263 could not survive. The Tribunal also held that the invalidity of the underlying reassessment could be raised in collateral or consequential proceedings even without a separate challenge to the reassessment order.
Reassessment completed under section 147 read with section 143(3) without issuance of mandatory notice under section 143(2) was held void by the ITAT. The record, including RTI material, did not show issuance of notice, and section 292BB was held to cure only defects in service, not the complete absence of notice. As the reassessment was a nullity, the consequential revision under section 263 could not survive. The Tribunal also held that the invalidity of the underlying reassessment could be raised in collateral or consequential proceedings even without a separate challenge to the reassessment order.
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