Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Non-disposal of an assessee's objections to reassessment reopening before completion of the assessment vitiates the reassessment, because disposal by a separate speaking order is a mandatory requirement and not a mere procedural formality. Applying its earlier decision in ITO v. Hardeep Singh, the ITAT held that the Assessing Officer had not decided the objections before finalising the reassessment. The annulment of the reassessment was therefore upheld, and the Revenue's reliance on Home Finders Housing Ltd. was not accepted.
Non-disposal of an assessee's objections to reassessment reopening before completion of the assessment vitiates the reassessment, because disposal by a separate speaking order is a mandatory requirement and not a mere procedural formality. Applying its earlier decision in ITO v. Hardeep Singh, the ITAT held that the Assessing Officer had not decided the objections before finalising the reassessment. The annulment of the reassessment was therefore upheld, and the Revenue's reliance on Home Finders Housing Ltd. was not accepted.
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