Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Reopening of assessment u/s 147 - no notice u/s 143(2) issued - It is not a mere formality but it given the jurisdiction to the A.O. to complete the assessment U/s 143(3) of the Act, therefore, non-issuance of notice U/s 143(2) of the Act vitiates the assessment proceedings. - the assessment proceedings completed without issuance of notice u/s 143(2) of the act and void ab-initio and liable to be quashed. - AT
Reopening of assessment u/s 147 - no notice u/s 143(2) issued - It is not a mere formality but it given the jurisdiction to the A.O. to complete the assessment U/s 143(3) of the Act, therefore, non-issuance of notice U/s 143(2) of the Act vitiates the assessment proceedings. - the assessment proceedings completed without issuance of notice u/s 143(2) of the act and void ab-initio and liable to be quashed. - AT
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