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

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