Interest on Wrongful Input Tax Credit is mandatory where excess transitional credit was retained and later reversed, and related objections were rejec...
Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
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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