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    <title>2025 (12) TMI 1112 - MADRAS HIGH COURT</title>
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    <description>Reassessment notices issued to a person treated as agent of a non-resident were held time barred because the special limitation period for that status had expired, and the general limitation argument could not override the specific statutory bar. Assessments framed on the basis that the assessee was an agent were also held invalid because no prior notice or order had been issued treating the assessee as agent for the relevant years, contrary to the statutory requirement of hearing and prior determination of representative status. The assessments and notices therefore could not be sustained.</description>
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      <link>https://www.taxtmi.com/caselaws?id=783572</link>
      <description>Reassessment notices issued to a person treated as agent of a non-resident were held time barred because the special limitation period for that status had expired, and the general limitation argument could not override the specific statutory bar. Assessments framed on the basis that the assessee was an agent were also held invalid because no prior notice or order had been issued treating the assessee as agent for the relevant years, contrary to the statutory requirement of hearing and prior determination of representative status. The assessments and notices therefore could not be sustained.</description>
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