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The High Court quashed the rectification notice, rectification order, and notice of demand issued u/s 154 of the Income Tax Act, holding that the order of determination made by the Designated Authority under the DTVSV Act attained finality and could not be reopened or revised by any authority under the Income Tax Act. The court observed that the determination made under the DTVSV Act is rendered final, except where the application is found to suffer from an incorrect declaration or suppression of material facts. The action u/s 154 did not fall within the ambit of the exception provided in Section 4(6) of the DTVSV Act. The court emphasized the legislative intent of the DTVSV Act to accord closure to tax disputes and the finality attached to the determination made thereunder.
The High Court quashed the rectification notice, rectification order, and notice of demand issued u/s 154 of the Income Tax Act, holding that the order of determination made by the Designated Authority under the DTVSV Act attained finality and could not be reopened or revised by any authority under the Income Tax Act. The court observed that the determination made under the DTVSV Act is rendered final, except where the application is found to suffer from an incorrect declaration or suppression of material facts. The action u/s 154 did not fall within the ambit of the exception provided in Section 4(6) of the DTVSV Act. The court emphasized the legislative intent of the DTVSV Act to accord closure to tax disputes and the finality attached to the determination made thereunder.
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