International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
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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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