Condonation of Delay denied: communication lapses and corporate restructuring found insufficient; prolonged inaction and lack of bona fides led to ref...
Export Support intervention INSIGHT launched to provide non financial capacity building, trade intelligence and pilot support with defined funding and...
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Validity of assessment proceedings under section 147 turned on omission to issue statutory notice under section 143(2). The tribunal applied precedent establishing that issuance of notice under section 143(2) is mandatory where the Assessing Officer considers it necessary to verify understatement of income or underpayment of tax, and failure to issue such notice is not a curable procedural irregularity; consequence: assessments completed under section 147 read with section 144 without the mandatory notice are vitiated and the assessment orders are null and void, resulting in decision against the revenue.
Validity of assessment proceedings under section 147 turned on omission to issue statutory notice under section 143(2). The tribunal applied precedent establishing that issuance of notice under section 143(2) is mandatory where the Assessing Officer considers it necessary to verify understatement of income or underpayment of tax, and failure to issue such notice is not a curable procedural irregularity; consequence: assessments completed under section 147 read with section 144 without the mandatory notice are vitiated and the assessment orders are null and void, resulting in decision against the revenue.
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