Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
The ITAT held that notices issued during assessment proceedings without digital or manual signatures are illegal, invalid, and inoperative, lacking jurisdictional validity. Consequently, non-compliance with such unsigned notices cannot constitute a default under section 272A(1)(d) of the Act. The penalty imposed on the assessee for alleged non-compliance was therefore unsustainable. The tribunal rejected the CIT(A)'s reasoning dismissing the assessee's contention, affirming that an unsigned notice is tantamount to no notice at all, and awareness of pending proceedings does not cure the defect or validate the notice. In view of these findings, the penalty levied under section 272A(1)(d) was quashed and the assessee's appeal was allowed.
The ITAT held that notices issued during assessment proceedings without digital or manual signatures are illegal, invalid, and inoperative, lacking jurisdictional validity. Consequently, non-compliance with such unsigned notices cannot constitute a default under section 272A(1)(d) of the Act. The penalty imposed on the assessee for alleged non-compliance was therefore unsustainable. The tribunal rejected the CIT(A)'s reasoning dismissing the assessee's contention, affirming that an unsigned notice is tantamount to no notice at all, and awareness of pending proceedings does not cure the defect or validate the notice. In view of these findings, the penalty levied under section 272A(1)(d) was quashed and the assessee's appeal was allowed.
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TaxTMI 
TaxTMI 
of 4918 
