Juridical seat versus arbitral venue determines supervisory court jurisdiction, while timely award challenges remain within the prescribed limitation ...
Reassessment procedure requires the Assessing Officer to furnish recorded reasons and decide objections to reopening by a speaking order before initiating scrutiny through a notice under section 143(2). A return filed in response to a reopening notice must be processed under the regular assessment procedure, but scrutiny cannot precede determination of jurisdictional objections. Further, no action, including a notice under section 142(1), may be taken for four weeks after service of an order rejecting objections. Notices issued contrary to these requirements, and consequential action, were quashed; the reopening challenge remained open.
Reassessment procedure requires the Assessing Officer to furnish recorded reasons and decide objections to reopening by a speaking order before initiating scrutiny through a notice under section 143(2). A return filed in response to a reopening notice must be processed under the regular assessment procedure, but scrutiny cannot precede determination of jurisdictional objections. Further, no action, including a notice under section 142(1), may be taken for four weeks after service of an order rejecting objections. Notices issued contrary to these requirements, and consequential action, were quashed; the reopening challenge remained open.
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