https://www.taxtmi.com/caselaws?id=470468 Prior determination of representative-assessee status is a jurisdictional prerequisite to reassessing an alleged agent of a non-resident. The proposed agent must receive the prescribed opportunity to contest that status before a reassessment notice is issued in that capacity; initiating reassessment first renders it invalid. Protective assessment is permissible only where genuine doubt exists about the person taxable on particular income and requires a substantive assessment in a taxpayer's case. Reopening solely for a protective assessment, without any substantive assessment identifying the taxable person, is unsustainable. The notes state that both defects deprived the reassessment of jurisdiction. 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 Prior determination of representative-assessee status is a jurisdictional prerequisite to reassessing an alleged agent of a non-resident. The proposed agent must receive the prescribed opportunity to contest that status before a reassessment notice is issued in that capacity; initiating reassessment first renders it invalid. Protective assessment is permissible only where genuine doubt exists about the person taxable on particular income and requires a substantive assessment in a taxpayer's case. Reopening solely for a protective assessment, without any substantive assessment identifying the taxable person, is unsustainable. The notes state that both defects deprived the reassessment of jurisdiction. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470468