Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
The ITAT held that the notice issued under section 142(1) was invalid as it failed to specify the sender, recipient, and subject, thereby not complying with the prescribed mode of transmission under section 144B(6)(ii)(a). Consequently, the notice was deemed not issued or served to the assessee. In the absence of evidence to the contrary, the tribunal ruled that the assessment order based on such defective notice is arbitrary, legally unsustainable, and void ab initio. Accordingly, the assessment was quashed, rendering all subsequent proceedings non-est in law. The appeal filed by the assessee was allowed.
The ITAT held that the notice issued under section 142(1) was invalid as it failed to specify the sender, recipient, and subject, thereby not complying with the prescribed mode of transmission under section 144B(6)(ii)(a). Consequently, the notice was deemed not issued or served to the assessee. In the absence of evidence to the contrary, the tribunal ruled that the assessment order based on such defective notice is arbitrary, legally unsustainable, and void ab initio. Accordingly, the assessment was quashed, rendering all subsequent proceedings non-est in law. The appeal filed by the assessee was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
