Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
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Electronic issuance of a reassessment notice occurs when it is dispatched through the ITBA system, not when digitally signed or generated. A notice recorded as issued on 1 April 2021 was therefore governed by the amended reassessment regime and required compliance with the pre-notice procedure under section 148A; its non-compliance rendered the notice invalid and vitiated the consequential reassessment order. Independently, where reassessment is initiated beyond three years from the end of the relevant assessment year, sanction must come from the specified higher authority under section 151(ii). Approval by the Principal Commissioner was incompetent, providing a separate ground to quash the notice.
Electronic issuance of a reassessment notice occurs when it is dispatched through the ITBA system, not when digitally signed or generated. A notice recorded as issued on 1 April 2021 was therefore governed by the amended reassessment regime and required compliance with the pre-notice procedure under section 148A; its non-compliance rendered the notice invalid and vitiated the consequential reassessment order. Independently, where reassessment is initiated beyond three years from the end of the relevant assessment year, sanction must come from the specified higher authority under section 151(ii). Approval by the Principal Commissioner was incompetent, providing a separate ground to quash the notice.
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