Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
Reopening of assessment was held invalid where the PCIT's approval consisted only of the terse statement "yes, I am satisfied" without recorded reasons; such mechanical approval fails the requirement that the approving officer must record satisfaction and reasons, rendering the issuance of notice and consequential assessment legally unsustainable. The tribunal relied on precedent holding similar formulaic endorsements inadequate, and accordingly quashed the notice for reopening and the assessment framed following that approval for want of valid administrative satisfaction.
Reopening of assessment was held invalid where the PCIT's approval consisted only of the terse statement "yes, I am satisfied" without recorded reasons; such mechanical approval fails the requirement that the approving officer must record satisfaction and reasons, rendering the issuance of notice and consequential assessment legally unsustainable. The tribunal relied on precedent holding similar formulaic endorsements inadequate, and accordingly quashed the notice for reopening and the assessment framed following that approval for want of valid administrative satisfaction.
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