https://www.taxtmi.com/caselaws?id=470468 Reassessment of an alleged agent of a non-resident requires prior determination of representative-assessee status after the prescribed opportunity to contest that status. This determination is a jurisdictional prerequisite because it preserves the proposed agent's statutory right to challenge liability in that capacity; reassessment initiated before it is invalid. Protective assessment is permissible only where there is genuine doubt about the person taxable on particular income. Reopening solely for a protective assessment cannot be sustained where no substantive assessment has been made in any taxpayer's hands. The reassessment was therefore invalid for both lack of prior representative-assessee determination and absence of a substantive assessment. en-us Fri, 21 Mar 2025 00:00:00 +0530 Tue, 28 Jul 2026 19:00:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470468 Reassessment of an alleged agent of a non-resident requires prior determination of representative-assessee status after the prescribed opportunity to contest that status. This determination is a jurisdictional prerequisite because it preserves the proposed agent's statutory right to challenge liability in that capacity; reassessment initiated before it is invalid. Protective assessment is permissible only where there is genuine doubt about the person taxable on particular income. Reopening solely for a protective assessment cannot be sustained where no substantive assessment has been made in any taxpayer's hands. The reassessment was therefore invalid for both lack of prior representative-assessee determination and absence of a substantive assessment. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470468