Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Reassessment requires a valid jurisdictional notice under section 143(2). Where a private company converted into an LLP and the Assessing Officer was notified of the conversion, issuing that notice and completing reassessment in the name of the erstwhile company rendered the proceedings invalid. A company and an LLP have separate legal identities and different tax treatment; assessment of the non-existent company was therefore a substantive illegality, not a procedural defect capable of cure under section 292B. The reassessment orders were void from inception and quashed, while remaining grounds became academic.
Reassessment requires a valid jurisdictional notice under section 143(2). Where a private company converted into an LLP and the Assessing Officer was notified of the conversion, issuing that notice and completing reassessment in the name of the erstwhile company rendered the proceedings invalid. A company and an LLP have separate legal identities and different tax treatment; assessment of the non-existent company was therefore a substantive illegality, not a procedural defect capable of cure under section 292B. The reassessment orders were void from inception and quashed, while remaining grounds became academic.
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