Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
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Issuance of a notice under section 143(2) is a jurisdictional requirement where a return is filed belatedly in response to an inquiry; absence of that notice renders any assessment completed under section 144 void. The tribunal found no material proving service of the mandatory notice and, following existing precedent, held the assessment without such notice invalid and quashed the assessment order, allowing the taxpayer's appeal.
Issuance of a notice under section 143(2) is a jurisdictional requirement where a return is filed belatedly in response to an inquiry; absence of that notice renders any assessment completed under section 144 void. The tribunal found no material proving service of the mandatory notice and, following existing precedent, held the assessment without such notice invalid and quashed the assessment order, allowing the taxpayer's appeal.
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