Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Dominant issue: whether an unsigned notice issued under Section 148 is valid. Reasoning: Section 282A mandates that notices issued by an Income-tax Authority must be signed; an unsigned notice is invalid ab initio. Reliance on Sections 292B/292BB to cure the defect is unsustainable because those provisions cannot revive a notice that is void for want of the statutorily required signature and such a construction would conflict with Section 282A. Outcome: the unsigned Section 148 notice is invalid and reassessment proceedings initiated thereon are invalid; decision for the assessee. - HC
Dominant issue: whether an unsigned notice issued under Section 148 is valid. Reasoning: Section 282A mandates that notices issued by an Income-tax Authority must be signed; an unsigned notice is invalid ab initio. Reliance on Sections 292B/292BB to cure the defect is unsustainable because those provisions cannot revive a notice that is void for want of the statutorily required signature and such a construction would conflict with Section 282A. Outcome: the unsigned Section 148 notice is invalid and reassessment proceedings initiated thereon are invalid; decision for the assessee. - HC
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