Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
The sole issue is validity of reassessment where notices under section 143(2) were issued manually without a computer-generated DIN. Relying on the CBDT circular making DIN mandatory from 01.10.2019 and permitting manual issue only with recorded reasons and prior written approval of CCIT/DGIT, the tribunal found Revenue could not produce recorded reasons or prior approval. Consequently the 143(2) communications are invalid and deemed never issued; assumption of jurisdiction under section 148 is vitiated and reassessment is quashed as void ab initio. - ITAT
The sole issue is validity of reassessment where notices under section 143(2) were issued manually without a computer-generated DIN. Relying on the CBDT circular making DIN mandatory from 01.10.2019 and permitting manual issue only with recorded reasons and prior written approval of CCIT/DGIT, the tribunal found Revenue could not produce recorded reasons or prior approval. Consequently the 143(2) communications are invalid and deemed never issued; assumption of jurisdiction under section 148 is vitiated and reassessment is quashed as void ab initio. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
