Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
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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