Proportionality in company penalty quantification requires aggravating and mitigating factors; mechanical multiplication of director liability is impe...
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A writ challenge to reassessment notices on the ground that the Jurisdictional Assessing Officer lacked authority under the reassessment regime between 01.04.2021 and 01.04.2024 failed, because the retrospective insertion of Section 147A altered the foundation of contrary decisions and the jurisdictional objection no longer survived. The constitutional challenge to the amended provision was not examined in the Single Judge writ proceedings, as such a vires attack had to be pursued before the Division Bench under the High Court Writ Rules. Recovery was kept in abeyance for 30 days to permit the petitioners to seek appropriate relief before the Division Bench.
A writ challenge to reassessment notices on the ground that the Jurisdictional Assessing Officer lacked authority under the reassessment regime between 01.04.2021 and 01.04.2024 failed, because the retrospective insertion of Section 147A altered the foundation of contrary decisions and the jurisdictional objection no longer survived. The constitutional challenge to the amended provision was not examined in the Single Judge writ proceedings, as such a vires attack had to be pursued before the Division Bench under the High Court Writ Rules. Recovery was kept in abeyance for 30 days to permit the petitioners to seek appropriate relief before the Division Bench.
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