Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Personal hearing requirements in GST adjudication were satisfied by prior opportunities and written submissions; appellate limitation received writ-pe...
A reassessment notice under Section 148 must be issued to a living and correctly identified assessee; a notice issued to a deceased person is void from inception. Proceedings may continue against a legal representative only if validly initiated during the deceased's lifetime, while fresh proceedings require a notice directly to the legal representative within the statutory limitation period. Section 292B cannot cure this foundational jurisdictional defect, and Section 292BB does not apply where the assessee died before notice issuance; participation or waiver cannot confer jurisdiction. Equitable considerations cannot validate the proceedings. Quashing the void notice is not a finding or direction under Section 150 permitting a time-barred fresh reassessment notice.
A reassessment notice under Section 148 must be issued to a living and correctly identified assessee; a notice issued to a deceased person is void from inception. Proceedings may continue against a legal representative only if validly initiated during the deceased's lifetime, while fresh proceedings require a notice directly to the legal representative within the statutory limitation period. Section 292B cannot cure this foundational jurisdictional defect, and Section 292BB does not apply where the assessee died before notice issuance; participation or waiver cannot confer jurisdiction. Equitable considerations cannot validate the proceedings. Quashing the void notice is not a finding or direction under Section 150 permitting a time-barred fresh reassessment notice.
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