Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
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Reopening initiated in the individual's name but assessment subsequently framed on an association of persons was held impermissible; the tribunal found that changing the assessed status from individual to AOP during reassessment vitiates jurisdiction and procedure, rendering the reassessment order invalid. Consequently the reassessment order was quashed and the taxpayer's appeal allowed, on the basis that assessment must remain within the status named in the reopening notice and cannot be altered to substitute or create a different taxable status.
Reopening initiated in the individual's name but assessment subsequently framed on an association of persons was held impermissible; the tribunal found that changing the assessed status from individual to AOP during reassessment vitiates jurisdiction and procedure, rendering the reassessment order invalid. Consequently the reassessment order was quashed and the taxpayer's appeal allowed, on the basis that assessment must remain within the status named in the reopening notice and cannot be altered to substitute or create a different taxable status.
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