Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
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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