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...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Collateral challenge to the jurisdiction of reassessment proceedings was held maintainable in an appeal against penalty where the penalty was founded on that reassessment. After three years from the end of the relevant assessment year, approval for notice under section 148 had to be obtained from the authority specified in section 151(ii); approval by the PCIT was insufficient. Because the notice under section 148 and the reassessment order were issued with the wrong sanction, the reassessment was void and the consequential penalty under section 271E could not survive.
Collateral challenge to the jurisdiction of reassessment proceedings was held maintainable in an appeal against penalty where the penalty was founded on that reassessment. After three years from the end of the relevant assessment year, approval for notice under section 148 had to be obtained from the authority specified in section 151(ii); approval by the PCIT was insufficient. Because the notice under section 148 and the reassessment order were issued with the wrong sanction, the reassessment was void and the consequential penalty under section 271E could not survive.
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