Failure to Record Satisfaction Renders Section 148 Notice Void & Assessment Order Void-ab-initio

ITO Vs Holiday Resort Corporation (ITAT Mumbai) The ITAT Mumbai ruling in ITO Vs Holiday Resort Corporation sheds light on the consequences of failure to record satisfaction for issuing a notice under Section 148 of the Income-tax Act. The assessment order was deemed void-ab-initio due to non-compliance with statutory provisions. Background of the Case The Revenue Department and the Assessee filed appeals and cross objections against the orders passed by the National Faceless Appeal Centre, Delhi, for the assessment years 2009-10 & 2007-08. The Assessee challenged the validity of the notic...