Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
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A composite show cause notice under Section 74 clubbing multiple financial years was held impermissible because the statutory scheme operates tax period-wise and year-wise, with separate return obligations and limitation consequences for each period. The Court followed its own binding precedent and held that authorities within its jurisdiction were bound by that view until stayed or overruled; dismissal in limine of a contrary challenge did not create merger on merits. The composite notice and consequential order were quashed, with liberty to issue a fresh notice strictly in accordance with law.
A composite show cause notice under Section 74 clubbing multiple financial years was held impermissible because the statutory scheme operates tax period-wise and year-wise, with separate return obligations and limitation consequences for each period. The Court followed its own binding precedent and held that authorities within its jurisdiction were bound by that view until stayed or overruled; dismissal in limine of a contrary challenge did not create merger on merits. The composite notice and consequential order were quashed, with liberty to issue a fresh notice strictly in accordance with law.
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