Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
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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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