International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
ITAT allowed the assessee's appeal, holding that the notice issued u/s 143(2) was unsigned and blank, thereby violating s. 282A(1) of the Act. The Tribunal found no material from the Revenue to rebut this factual defect. Consequently, the notice u/s 143(2) was declared invalid, arbitrary, and void ab initio. As the foundational notice itself was void, the AO lacked valid inherent jurisdiction to frame the assessment u/s 143(3)/147 r.w.s. 263/144B. The resultant reassessment order was therefore quashed in entirety, granting full relief to the assessee.
ITAT allowed the assessee's appeal, holding that the notice issued u/s 143(2) was unsigned and blank, thereby violating s. 282A(1) of the Act. The Tribunal found no material from the Revenue to rebut this factual defect. Consequently, the notice u/s 143(2) was declared invalid, arbitrary, and void ab initio. As the foundational notice itself was void, the AO lacked valid inherent jurisdiction to frame the assessment u/s 143(3)/147 r.w.s. 263/144B. The resultant reassessment order was therefore quashed in entirety, granting full relief to the assessee.
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