Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
The assessee challenged the order before the CIT(A) both on merits as well as on jurisdiction and the limitation grounds - Ld. CIT(A) ought to have first decided the jurisdictional issue and only thereafter should have proceeded to decide the issue on merits if so warranted in law - AT
The assessee challenged the order before the CIT(A) both on merits as well as on jurisdiction and the limitation grounds - Ld. CIT(A) ought to have first decided the jurisdictional issue and only thereafter should have proceeded to decide the issue on merits if so warranted in law - AT
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