https://www.taxtmi.com/caselaws?id=798411 Reassessment jurisdiction requires a valid statutory notice, clear and specific jurisdictional satisfaction, and approval showing independent scrutiny. Omnibus notices that retain mutually inapplicable contingencies without identifying the relevant search, documents, or alleged income fail to establish jurisdiction. A reassessment cannot materially depart from the recorded satisfaction by adopting a different basis for taxing the transaction. Where reliance is placed on third-party material or statements, the affected person must receive the underlying material and an effective opportunity for cross-examination when specifically requested. Defective notice, vague satisfaction, mechanical approval, and denial of procedural fairness render the reassessment proceedings and resulting order void from inception. en-us Wed, 29 Jul 2026 00:00:00 +0530 Mon, 07 Sep 2026 08:48:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798411 Reassessment jurisdiction requires a valid statutory notice, clear and specific jurisdictional satisfaction, and approval showing independent scrutiny. Omnibus notices that retain mutually inapplicable contingencies without identifying the relevant search, documents, or alleged income fail to establish jurisdiction. A reassessment cannot materially depart from the recorded satisfaction by adopting a different basis for taxing the transaction. Where reliance is placed on third-party material or statements, the affected person must receive the underlying material and an effective opportunity for cross-examination when specifically requested. Defective notice, vague satisfaction, mechanical approval, and denial of procedural fairness render the reassessment proceedings and resulting order void from inception. Case-Laws Income Tax Wed, 29 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798411