Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
A liberal approach governs condonation where refusal would defeat substantial justice, and the death of the authorised representative handling the assessee's tax matters in the faceless regime constituted sufficient cause for the 430-day delay. The Court also held that a jurisdictional objection that reassessment may be void for want of approval under law cannot be excluded by a rigid or hyper-technical limitation analysis. By refusing condonation solely for lack of documentary support and not addressing the pleaded defect, the Tribunal misdirected itself. The delay was condoned, the limitation dismissal was set aside, and the appeal was remanded for fresh adjudication, with the Section 151 validity issue to be decided as a preliminary issue.
A liberal approach governs condonation where refusal would defeat substantial justice, and the death of the authorised representative handling the assessee's tax matters in the faceless regime constituted sufficient cause for the 430-day delay. The Court also held that a jurisdictional objection that reassessment may be void for want of approval under law cannot be excluded by a rigid or hyper-technical limitation analysis. By refusing condonation solely for lack of documentary support and not addressing the pleaded defect, the Tribunal misdirected itself. The delay was condoned, the limitation dismissal was set aside, and the appeal was remanded for fresh adjudication, with the Section 151 validity issue to be decided as a preliminary issue.
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