Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
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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