Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Service of a reassessment notice under section 148 is a jurisdictional condition precedent for valid assumption of reassessment power. Where the revenue could not produce proof of effective delivery, including a tracking report or other evidence of service, mere generation or dispatch of the notice was held insufficient. The absence of valid service deprived the assessee of an opportunity to place material before the AO and vitiated the reassessment. The HC quashed the assessment order and remanded the matter for fresh consideration after due notice and opportunity to respond.
Service of a reassessment notice under section 148 is a jurisdictional condition precedent for valid assumption of reassessment power. Where the revenue could not produce proof of effective delivery, including a tracking report or other evidence of service, mere generation or dispatch of the notice was held insufficient. The absence of valid service deprived the assessee of an opportunity to place material before the AO and vitiated the reassessment. The HC quashed the assessment order and remanded the matter for fresh consideration after due notice and opportunity to respond.
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