Reopening assessments by issuing a notice for reassessment...

Reopening assessments by issuing a notice for reassessment beyond three years is invalid where the statutory conditions for extended reassessment and required sanction/approval were not satisfied; such notices are void ab initio and the consequent assessment orders are liable to be quashed. Where initial reassessment proceedings were dropped, issuing a fresh reassessment notice without first following the mandated pre-reopening consultation and disposal procedure is contrary to the reassessment scheme and therefore invalid; a second notice issued on the same recorded reasons without complying with that procedure is quashed along with resulting assessment orders.

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