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    <title>2022 (4) TMI 862 - BOMBAY HIGH COURT</title>
    <link>https://www.taxtmi.com/caselaws?id=421196</link>
    <description>The High Court held that the notice issued under Section 21 of the E.T. Act by the Assistant Commissioner of Income Tax was without jurisdiction, emphasizing that only the Commissioner has the authority for such notices. It was ruled that the Commissioner cannot base revision orders on notices issued by subordinate officers, highlighting the necessity for personal application of mind. The principle of waiver was deemed inapplicable to confer jurisdiction, and delegation of powers must be expressly authorized by law. The Court decided in favor of the respondent/assessee, stressing the importance of adherence to statutory provisions. The appeal was dismissed without costs.</description>
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    <pubDate>Wed, 13 Apr 2022 00:00:00 +0530</pubDate>
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      <title>2022 (4) TMI 862 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=421196</link>
      <description>The High Court held that the notice issued under Section 21 of the E.T. Act by the Assistant Commissioner of Income Tax was without jurisdiction, emphasizing that only the Commissioner has the authority for such notices. It was ruled that the Commissioner cannot base revision orders on notices issued by subordinate officers, highlighting the necessity for personal application of mind. The principle of waiver was deemed inapplicable to confer jurisdiction, and delegation of powers must be expressly authorized by law. The Court decided in favor of the respondent/assessee, stressing the importance of adherence to statutory provisions. The appeal was dismissed without costs.</description>
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      <pubDate>Wed, 13 Apr 2022 00:00:00 +0530</pubDate>
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