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...
Sanction for reassessment beyond three years must be granted by the authority specified in section 151(ii) as it stood prior to the 01.04.2023 amendment; approval by a Principal Commissioner not so empowered rendered the sanction invalid. Relying on binding jurisdictional precedent, the article explains that the proviso inserted w.e.f. 01.04.2023 cannot be applied retrospectively, and consequently notices issued under section 148, orders under section 148A(d) and all consequential reassessment proceedings lacked valid sanction and were quashed. The Tribunal therefore did not address the substantive additions.
Sanction for reassessment beyond three years must be granted by the authority specified in section 151(ii) as it stood prior to the 01.04.2023 amendment; approval by a Principal Commissioner not so empowered rendered the sanction invalid. Relying on binding jurisdictional precedent, the article explains that the proviso inserted w.e.f. 01.04.2023 cannot be applied retrospectively, and consequently notices issued under section 148, orders under section 148A(d) and all consequential reassessment proceedings lacked valid sanction and were quashed. The Tribunal therefore did not address the substantive additions.
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