Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under sect...
Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Proceeds of crime: provisional attachment confirmed; equivalent value attachment and acquisition date fair market value upheld, Covid exclusion preser...
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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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