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Reassessment notices issued beyond three years require prior approval from the higher specified authority prescribed by section 151(ii); approval by a Principal Commissioner is insufficient, invalidating the notice and consequential assessment. Where an assessee asks that an original return be treated as the return filed in response to reassessment proceedings, a notice under section 143(2) becomes mandatory, and its omission invalidates the assessment. The inadequate-consideration provision for immovable property does not apply prospectively where the agreement, full payment and possession established completion of the purchase before the amendment took effect, despite later registration.
Reassessment notices issued beyond three years require prior approval from the higher specified authority prescribed by section 151(ii); approval by a Principal Commissioner is insufficient, invalidating the notice and consequential assessment. Where an assessee asks that an original return be treated as the return filed in response to reassessment proceedings, a notice under section 143(2) becomes mandatory, and its omission invalidates the assessment. The inadequate-consideration provision for immovable property does not apply prospectively where the agreement, full payment and possession established completion of the purchase before the amendment took effect, despite later registration.
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