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...
Reopening assessments beyond three years requires prior approval from the specified authority; approval must be from PCCIT or PDGIT, or if none exist, from CCIT or DGIT under the procedural mandate, and failure to obtain such specified-authority sanction renders notices issued under section 148 void for want of jurisdiction. The procedural requirements of Section 151 are mandatory and cannot be satisfied by any other officers concurrence; accordingly, a notice issued without the prescribed specified-authority approval is invalid and liable to be quashed, resulting in relief to the taxpayer.
Reopening assessments beyond three years requires prior approval from the specified authority; approval must be from PCCIT or PDGIT, or if none exist, from CCIT or DGIT under the procedural mandate, and failure to obtain such specified-authority sanction renders notices issued under section 148 void for want of jurisdiction. The procedural requirements of Section 151 are mandatory and cannot be satisfied by any other officers concurrence; accordingly, a notice issued without the prescribed specified-authority approval is invalid and liable to be quashed, resulting in relief to the taxpayer.
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