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...
Reopening after a scrutiny assessment was invalid where the recorded reasons incorrectly stated that the return had only been processed under limited processing and, on that false premise, invoked the deeming escapement provision. Because the original assessment had in fact been completed under scrutiny assessment, the Tribunal held that the recorded reasons disclosed clear non-application of mind. The reassessment proceedings were therefore held void ab initio, bad in law and quashed.
Reopening after a scrutiny assessment was invalid where the recorded reasons incorrectly stated that the return had only been processed under limited processing and, on that false premise, invoked the deeming escapement provision. Because the original assessment had in fact been completed under scrutiny assessment, the Tribunal held that the recorded reasons disclosed clear non-application of mind. The reassessment proceedings were therefore held void ab initio, bad in law and quashed.
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