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HC invalidated reassessment proceedings against the assessee, finding procedural irregularities in notice issuance. The order under Section 148A(d) was determined to be beyond the prescribed limitation period. The court ruled that the notice was issued without mandatory approval from the specified authority under Section 151, rendering the entire reassessment process invalid. The impugned notice, assessment order, and consequent demand were set aside, effectively protecting the assessee from unauthorized tax reassessment. The decision emphasized strict adherence to procedural timelines and statutory requirements in tax reassessment proceedings.
HC invalidated reassessment proceedings against the assessee, finding procedural irregularities in notice issuance. The order under Section 148A(d) was determined to be beyond the prescribed limitation period. The court ruled that the notice was issued without mandatory approval from the specified authority under Section 151, rendering the entire reassessment process invalid. The impugned notice, assessment order, and consequent demand were set aside, effectively protecting the assessee from unauthorized tax reassessment. The decision emphasized strict adherence to procedural timelines and statutory requirements in tax reassessment proceedings.
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