Change of corporate management after approved resolution plan - writ maintainable; property attachment not 'transfer' under PBPT; Section 32A protecti...
Annuloplasty band classification as implanted therapeutic appliance, not anatomical replacement, resulting in classification under tariff heading for ...
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.
Note: It is a system-generated summary and is for quick reference only.