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...
Whether a Jurisdictional Assessing Officer (JAO) can initiate proceedings under Sections 148A and 148 after implementation of the Faceless Scheme: relying on precedent that post- Faceless Scheme initiation and issuance of notices by the JAO is ultra vires and per se illegal, the court held such notices and consequential assessments unsustainable; therefore the impugned notices under Sections 148A/148 and all orders flowing therefrom are quashed. Relief is granted on jurisdictional grounds, while liberty is reserved to the revenue to pursue further action as indicated by the court. - HC
Whether a Jurisdictional Assessing Officer (JAO) can initiate proceedings under Sections 148A and 148 after implementation of the Faceless Scheme: relying on precedent that post- Faceless Scheme initiation and issuance of notices by the JAO is ultra vires and per se illegal, the court held such notices and consequential assessments unsustainable; therefore the impugned notices under Sections 148A/148 and all orders flowing therefrom are quashed. Relief is granted on jurisdictional grounds, while liberty is reserved to the revenue to pursue further action as indicated by the court. - HC
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