https://www.taxtmi.com/caselaws?id=465927 Review addresses validity of reopening assessments where reasons recorded, satisfaction note and sanction are defective and arbitrary; arbitrariness and non-application of mind in recording reasons render the reasons-taking process unlawful, therefore reassessment initiated on that basis is vitiated and liable to be quashed. The requirement that statutory acts be performed in the prescribed manner (expressio unius est exclusio alterius) was applied to reject post-facto or improper sanctioning; a perfunctory statement of satisfaction was held inadequate, producing nullity of the reassessment proceedings. en-us Mon, 06 Nov 2023 00:00:00 +0530 Thu, 15 Jan 2026 14:44:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465927 Review addresses validity of reopening assessments where reasons recorded, satisfaction note and sanction are defective and arbitrary; arbitrariness and non-application of mind in recording reasons render the reasons-taking process unlawful, therefore reassessment initiated on that basis is vitiated and liable to be quashed. The requirement that statutory acts be performed in the prescribed manner (expressio unius est exclusio alterius) was applied to reject post-facto or improper sanctioning; a perfunctory statement of satisfaction was held inadequate, producing nullity of the reassessment proceedings. Case-Laws Income Tax Mon, 06 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465927