Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Threshold for allottee-initiated insolvency petitions in leasehold real estate upheld; petition admitted after possession letters deemed legally ineff...
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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