Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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