Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
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Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
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Unsigned approval under section 151 for reassessment was treated as invalid because section 282A(1) requires electronic tax documents to be signed. Following its earlier rulings, the ITAT held that this signature requirement is mandatory; where the approval bore no signature, it was void ab initio. As the foundational approval itself was unlawful, the reassessment proceedings based on it could not survive and the assessment was unsustainable.
Unsigned approval under section 151 for reassessment was treated as invalid because section 282A(1) requires electronic tax documents to be signed. Following its earlier rulings, the ITAT held that this signature requirement is mandatory; where the approval bore no signature, it was void ab initio. As the foundational approval itself was unlawful, the reassessment proceedings based on it could not survive and the assessment was unsustainable.
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