Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
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Section 282A(1) requires that every notice or document issued by an income tax authority be signed, whether in paper form or electronically; the deeming/authentication provision in subsection (2) does not supplant the mandatory signing requirement in subsection (1). An unsigned approval or notice therefore breaches the statutory mandate, is arbitrary and void ab initio, and cannot vest the Assessing Officer with jurisdiction to proceed under reassessment provisions. Consequent reassessment steps are non est, and the reassessment proceedings must be quashed.
Section 282A(1) requires that every notice or document issued by an income tax authority be signed, whether in paper form or electronically; the deeming/authentication provision in subsection (2) does not supplant the mandatory signing requirement in subsection (1). An unsigned approval or notice therefore breaches the statutory mandate, is arbitrary and void ab initio, and cannot vest the Assessing Officer with jurisdiction to proceed under reassessment provisions. Consequent reassessment steps are non est, and the reassessment proceedings must be quashed.
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