Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
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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