Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
Issue concerns validity of a transfer order and subsequent assessment where the transferring authority lacked jurisdiction. The tribunal found that transfer provisions apply only when the assessing officer is vested with jurisdiction following a valid direction; absent jurisdiction, objection under the transfer provision cannot arise. The transfer order issued by a non-jurisdictional officer was held void ab initio, and consequential proceedings including the final assessment were without jurisdiction and therefore quashed. Failure to communicate the transfer order to the taxpayer until tribunal proceedings was noted as reinforcing the invalidity of the transfer and downstream assessment.
Issue concerns validity of a transfer order and subsequent assessment where the transferring authority lacked jurisdiction. The tribunal found that transfer provisions apply only when the assessing officer is vested with jurisdiction following a valid direction; absent jurisdiction, objection under the transfer provision cannot arise. The transfer order issued by a non-jurisdictional officer was held void ab initio, and consequential proceedings including the final assessment were without jurisdiction and therefore quashed. Failure to communicate the transfer order to the taxpayer until tribunal proceedings was noted as reinforcing the invalidity of the transfer and downstream assessment.
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