Proportionality in company penalty quantification requires aggravating and mitigating factors; mechanical multiplication of director liability is impe...
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Reopening of assessment - Jurisdiction of AO - AO, Mumbai who has issued the notice u/s 148 was not having jurisdiction as only AO, Dehradun was having the jurisdiction as per Notification, even the notice issued by AO, Mumbai was never served upon the assessee - entire reopening proceedings and consequent reassessment is void ab initio - AT
Reopening of assessment - Jurisdiction of AO - AO, Mumbai who has issued the notice u/s 148 was not having jurisdiction as only AO, Dehradun was having the jurisdiction as per Notification, even the notice issued by AO, Mumbai was never served upon the assessee - entire reopening proceedings and consequent reassessment is void ab initio - AT
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