Estate of Late Rangalal Jajodia v. CIT

79 ITR 505Supreme Court of India1971#4718 most cited

What is Estate of Late Rangalal Jajodia v. CIT authority for?

An omission or defect in serving a notice required by procedural provisions does not invalidate a tax liability created by substantive charging sections, making the assessment irregular but not void.

25

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2012 to 2025.

Also referred to as

Estate of Late Rangalal Jajodia v. CIT · 79 ITR 505 · SC · 1971 · section 148 · notice defect · procedural provision · substantive liability · assessment irregularity · void assessment · section 159

Sections most often in play

Section 148Section 142(1)Section 147Section 148A(b)Section 149Section 159Section 250Section 292B
Read the full judgment

Issues it is cited on

section 21service of noticenotice under section 148section 12section 142scrutiny assessmentassistant commissionersection 142(1)section 148section 147section 14total income

Judgments citing Estate of Late Rangalal Jajodia v. CIT

Rehana Parveen, Mangalore vs. Income Tax Officer, Ward 6(3)(1), Bangalore

In the result, appeal of the assesseeis allowed

ITA 38/BANG/2025[2015-16]Status: DisposedITAT Bangalore29 Jul 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2015-16

For Appellant: Shri. Balram R Rao, AdvocateFor Respondent: Shri. Ganesh R. Ghale, Advocate, Standing Counsel for Revenue
Section 148Section 148ASection 149

…being issued after obtaining approval of the PCIT KARNATAKA & GOA accorded on date 22/03/2022 vide reference No. 10000029669480. 7. He has filed a note wherein he has relied on the judgment in the case of Estate of Late RangalalJajodia Vs. CIT, Madras (1971) 79 ITR 505 (SC). 8. Considering the rival submissions, we noted that the AO has issued notice under section 148A(b) of the Act on 23.03.2022 with DIN No.ITBA/AST/F/148A/(SCN)/2021-22/1041357236(1) and time was granted upto 27.03.2022 which is less than 7 days but less than the minimum statutory period granted as per section of 18A(b) of the Act. For the sak…

ACIT-16(2), Mumbai, Aayakar Bhavan vs. Fakhruddin Taiyebali Padaria, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 5500/MUM/2024[2017-18]Status: DisposedITAT Mumbai07 Jan 2025AY 2017-18

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhailassessment Year: 2017-18 Acit- 16(2), Mumbai Fakhruddin Taiyebali Padaria 5Th Floor, Shabbir Place, 80 Vs. Dr. A.L. Nair Road, Mumbai- 400008. Pan: Abdpp 7103 P (Appellant) (Respondent) Present For: Assessee By : None Revenue By : Shri Dinesh A Chourasia, Sr. Dr Date Of Hearing : 03.12.2024 Date Of Pronouncement : 07.01.2025

For Appellant: NoneFor Respondent: Shri Dinesh A Chourasia, Sr. DR
Section 144Section 147Section 148Section 159Section 250Section 292BSection 69A

…ion 159 in the present Act) is not void or illegal and that any infractions in that behalf can be waived by the assessee. The court also placed reliance upon its earlier decision in Estate of Late Rangalal Jajodia v. Commissioner of Income Tax, Madras, (1971) 79 ITR 505, for the proposition that an omission to serve or any defect in the service of notices provided by procedural provisions does not efface or erase the liability to pay tax where such liability is created by distinct substantive provisions (charging sections). Any such omission or defect may render the order made irregular - depending upon the natur…

Late Sh. Birdi Chand Through Legal Heir Mukesh Sharma, Jaipur vs. ITO, Ward-7(2), Jaipur

In the result, the appeal of the assessee is allowed

ITA 502/JPR/2023[2012-13]Status: DisposedITAT Jaipur09 Apr 2024AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Anup Singh (Addl.CIT)
Section 139(1)Section 142(1)Section 143(3)Section 148Section 292BSection 54F

…tion 159 in the present Act) is not void or illegal and that any infractions in that behalf can be waived by the assessee. The court also placed reliance upon its earlier decision in Estate of Late RangalalJajodia v. Commissioner of Income Tax, Madras, [1971] 79 ITR 505, for the proposition that an omission to serve or any defect in the service of notices provided by procedural provisions does not efface or erase the liability to pay tax where such liability is created by distinct substantive provisions (charging sections). Any such omission or defect may render the order made irregular - depending upon the natur…

Sri. Annesh, Udupi vs. Income-Tax Officer, Ward-1, Chikmangalur

In the result, the appeal of the assessee is allowed

ITA 1179/BANG/2022[2012-13]Status: DisposedITAT Bangalore23 Feb 2023AY 2012-13

Bench: Shri Chandra Poojari

For Appellant: Shri S.V. Ravishankar, A.RFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for Department
Section 124Section 127Section 144Section 147Section 234

…ITA No.1179/Bang/2022 Sri Annesh, Udupi IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” “C’’ BENCH: BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER ITA No.1179/Bang/2022) Assessment Year: 2012-13 Sri Annesh H.No.2-28(F1) Deeksha Nilaya, Vidyaranya Nagara, Hirebettu Village, Herebettu Post Vs. ITO Ward-1 Parkala Chikmagalur Udupi 576 107 PAN NO : AZSPA7704Q APPELLANT RESPONDENT Appellant by : Shri S.V. Ravishankar, A.R. Respondent by : Shri Ganesh R. Ghale, Standing Counsel for Department Date of Hearing : 08.02.2023 Date of Pronouncement : 23.02.2023 O R D E R This appeal by assessee is directed ag…

Namrata Kapale, Chindwara vs. Pr.CIT-1, Jabalpur

In the result, the assessee‟s appeal is dismissed

ITA 41/JAB/2022[2017-18]Status: DisposedITAT Jabalpur08 Aug 2022AY 2017-18

Bench: Shri Sanjay Arora, Hon‟Ble & Shri Manomohan Das, Hon'Ble

For Appellant: Shri Rahul Bardia, FCAFor Respondent: Shri U.B. Mishra, CIT-DR
Section 143(2)Section 143(3)Section 148(1)Section 159(2)(b)Section 263

…IN THE INCOME TAX APPELLATE TRIBUNAL JABALPUR BENCH, JABALPUR (through web-based video conferencing platform) BEFORE SHRI SANJAY ARORA, HON‟BLE ACCOUNTANT MEMBER & SHRI MANOMOHAN DAS, HON'BLE JUDICIAL MEMBER I.T.A. No. 41/JAB/2022 (Asst. Year: 2017-18) Namrata Kapale, vs. Principal CIT-1, L/R of Ram Rao Kapale, Jabalpur. Ward No.12, Purani Basti Loniya, Karbal, Chhindwara. [PAN : FFUPK 7400 E] (Appellant) (Respondent) Appellant by : Shri Rahul Bardia, FCA Respondent by : Shri U.B. Mishra, CIT-DR Date of hearing : 08/08/2022 Date of pronouncement : 23/09/2022 O R D E R Per Sanjay Arora, AM: This is an Appeal…

Saurabh Singhai L/H Late Shri Mahendra Kumar Jain, Sagar vs. Income Tax Officer-3 Sagar, Sagar

In the result, the assessee‟s appeal is dismissed

ITA 5/JAB/2019[2010-11]Status: DisposedITAT Jabalpur29 Jul 2022AY 2010-11

Bench: Sh. Sanjay Arora, Hon'Ble & Sh. Manomohan Das, Hon‟Ble

Section 139Section 143(3)Section 147Section 148(1)Section 263

…wed opportunity of being heard before passing the order under reference; the defects in procedure – except where fundamental, affecting the jurisdiction, being saved by sec. 292B. Reference therein is also made to Estate of Late Rangalal Jajodia v. CIT [1971] 79 ITR 505 (SC), which has a bearing on the effect of a defect in the assessment arising out of want of notice to the LR and mis-description or mistake of name in the assessment order. Section 159, it explains, does not bear upon the jurisdiction of the taxing authority, but deals with matters incidental to it. The decision in Sumantbhai C. Munshaw (Decd.),…

Nandlal L. Kodnaney, Mumbai vs. ITO 26(2)(4), Mumbai

In the result, both the assessee’s appeals are dismissed

ITA 4924/MUM/2014[1992-93]Status: DisposedITAT Mumbai21 Aug 2020AY 1992-93

Bench: Shri Sanjay Arora & Shri Vikas Awasthy

For Appellant: Shri Mayur A. Shah, CAFor Respondent: Ms. Kavita P. Kaushik (Sr. DR)
Section 139Section 143(2)Section 147Section 148Section 148(1)

…said words in the context of s. 251, i.e., as it stood prior to its amendment by the Finance Act, 2001 w.e.f. 01.6.2001. The said understanding would obtain even in the context of s. 153(2A). Much earlier, the Apex Court in Late Rangalal Jajodia v. CIT [1971] 79 ITR 505 (SC), dealing with the case of setting aside of assessment, directing the assessing authority to make fresh assessment after giving notice to the heirs/executrix, held that the fresh assessments were not barred by time in view of second proviso to s. 34(3) of the 1922 Act (corresponding to s. 153(3)(ii) of the Act) as the issue of notice to the he…

Late Shri Navinchandra Sakalchand Dalal, Legal Heri Dipak N. Dalal, Ahmedabad vs. ITO, Ward-5(2)(3)., Ahmedabad

In the result the appeal of the assessee is allowed for the statistical purposes

ITA 415/AHD/2018[2012-13]Status: DisposedITAT Ahmedabad09 Mar 2020AY 2012-13

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./I.T.A. No. 415/Ahd/2018 ("नधा"रण वष" / Assessment Years : 2012-13)

For Appellant: Shri S. N. Divatia, A.R
Section 143(3)Section 148

…orders made were null and void. They were not. At worst, they were defective proceedings or irregular proceedings, as had been rightly held by the AAC and the Tribunal. The principle emerging from the decision in Estate of Late Rangalal Jajodia v. CIT [1971] 79 ITR 505 (SC), is that an omission to serve or any defect in the service of notices provided by procedural provisions does not efface or erase the liability to pay tax, where such liability is created by distinct substantive provisions. Any such omission or defect may render the order made irregular depending upon the nature of the provision not complied w…

Major Singh, Amritsar vs. The Income Tax Officer, Amritsar

In the result, the assessee’s appeal is partly allowed on the afore-said terms

ITA 426/ASR/2015[2005-06]Status: DisposedITAT Amritsar01 Jul 2019AY 2005-06

Bench: Sh. Sanjay Arorai.T.A. No. 426/Asr/2015 Assessment Year: 2005-06

For Appellant: Sh. Ashwani Kalia (Adv.)For Respondent: Sh. Charan Dass (D.R.)
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 148(1)

…precisely what stands clarified in the context of different notices, including u/s. 23(2) (under the I.T. Act, 1922, corresponding to s.143(2) under the Act, (viz. CIT v. Jai Prakash Singh [1996] 219 ITR 737 (SC); Estate of Late Rangalal Jajodia v. CIT [1971] 79 ITR 505 (SC). De hors its jurisdictional aspect, s. 143(2) notice is toward verification of return of income. The function of a notice, explained in many a case by the Hon’ble Apex Court, viz. (CST v. Subhash & Co., in C.A. No. 1374 of 2003, dated 17/2/2003); Jai Prakash Singh (supra); Estate of Late Rangalal Jajodia (supra)), is to put the assessee (noti…

Shri H.K. Gandotra, Gurgaon vs. The Inocme-Tax Officer, Jammu

In the result, the assessee’s appeal is dismissed

ITA 594/ASR/2014[1997-98]Status: DisposedITAT Amritsar27 Jun 2019AY 1997-98

Bench: Sh. Sanjay Arorai.T.A. No. 594/Asr/2014 Assessment Year: 1997-98

For Appellant: Sh. P. N. Arora (Adv.)For Respondent: Sh. Charan Dass (D.R.)
Section 143(3)Section 246Section 271(1)(c)Section 275

…r its’ several decision by the Hon’ble Apex Court, to some of which reference is being made here (CST v. Subhash & Co., in C.A. No. 1374 of 2003, dated 17/2/2003); CIT v. Jai Prakash Singh [1996] 219 ITR 737 (SC); Estate of Late Rangalal Jajodia v. CIT [1971] 79 ITR 505 (SC)), is to put the assessee (noticee) to notice about the contemplated proceedings; in the present case seeking explanation as to why, in view of being unable to explain the source of investment, i.e., to the extent of Rs.10.20 lacs, as well as the expenditure incurred on the marriage of his daughter, and the concomitant deeming thereof as his i…

Sh. Jaspal Singh S/O Sh. Swaran Singh, Amritsar vs. The Income Tax Officer, Amritsar

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 445/ASR/2016[2004-05]Status: DisposedITAT Amritsar08 May 2019AY 2004-05

Bench: Sh. Sanjay Arorai.T.A. No. 445/Asr/2016 Assessment Year: 2004-05

For Appellant: Sh. Padam Bahl (C.A.)For Respondent: Sh. Charan Dass (D.R.)
Section 144Section 154

…the noticee to notice that the proceedings in his case have been initiated, affording him an opportunity to comply with the said notice as well as to present his case in the matter. Lack of notice, as explained in Estate of Late Rangalal Jajodia v. CIT [1971] 79 ITR 505 (SC), noted with approval in CIT v. Jai Prakash Singh [1996] 219 ITR 737 (SC), to which reference was made by the Bench during hearing, rendered after a review of the judicial precedents, including Maharaja of Patiala vs. CIT (1943) 11 ITR 202 (Bom), also quoting therefrom, would not annul the proceedings but render the same procedurally infirm, i…

The Pr. Commissioner of Income Tax vs. M/S Bioplus Life Sciences Pvt Ltd

In the result, I pass the following:-

ITA/1014/2017HC Karnataka24 Jul 2018

Bench: The Hon'Ble Mr.Justice S.R.Krishna Kumar Writ Petition No.1014 Of 2017 (T-Kst) Between: M/S. Rainbow Colour Lab, No.13, D.J.C. Complex, Hudson Circle, Bengaluru – 560 027. A Partnership Firm Represented By Its Partner Sri.G.K.Madan Mohan, Aged About 62 Years, S/O Sri.G.V.Krishna Reddy. ...Petitioner (By Sri. M.Thirumalesh, Advocate ) And: 1. State Of Karnataka

Section 12

…te Assistant Commissioner was competent to set aside the assessment of an association of persons and to direct the Income Tax Officer to assess the members individually. 21. In the case of Estate of Late Rangalal Jajodia v. CIT [(1970) 3 SCC 371 : (1971) 79 ITR 505] the return had been filed by one Rangalal Jajodia who died before the assessment order was made. The assessment order showed the name of the assessee - 30 - as the estate of late Shri Rangalal Jajodia by legal heirs and representatives (these being the son, the (second) wife and her children. No notice, however, was served on the wife.…

Sh. Manish Periwal, Kolkata vs. DCIT, New Delhi

In the result, the assessee’s appeal stands dismissed

ITA 5156/DEL/2014[2006-07]Status: DisposedITAT Delhi04 Oct 2017AY 2006-07

Bench: Shri G.D. Agrawal, Hon’Ble & Shri Sudhanshu Srivastava

For Appellant: Ms Shweta Bansal, CAFor Respondent: Shri Atiq Ahmad, Sr. DR
Section 132Section 142(1)Section 153ASection 271Section 271(1)(b)

…tion of levying penalty without initiating the same and levying the penalty at Rs. 30,000/- while show cause notice was for Rs. 10,000/- only. The Ld. CIT (A) ITA 5156/D/2014 Assessment year 2006-07 has also relied on the case law of Rangalal Jajodia vs CIT, 79 ITR 505 (SC). In this case the issue was that notice for assessment was given to one legal representative and not to the other. This is not the case where penalty was not initiated. In the case of the appellant penalty was not initiated at all for the defaults for which penalty has been levied. The Ld. CIT (A) has further relied on the case law of Isha Be…

Sh. Manish Periwal, Kolkata vs. DCIT, New Delhi

In the result, assessee’s appeals are dismissed

ITA 5162/DEL/2014[2012-13]Status: PendingITAT Delhi08 Jun 2017AY 2012-13

Bench: Sh. Ramesh. P. Tolani & Sh. Prashant Maharishi

For Appellant: NoneFor Respondent: Sh. Rajesh Kumar, Sr. DR
Section 132Section 142Section 142(1)Section 153ASection 271Section 271(1)(b)Section 274

…Sections 271 and 272A.” 6. Ld. CIT(A) in support of his decision relied on following judgments: 7 ITA No. 5157-5162/Del/2014 (Manish Periwal ) (a) Dhakeswari Cotton Mills Ltd. V. CIT [1955] 27 ITR 126 (SC) (b) Estate of Late Rangalal Jajodia V. CIT [1971] 79 ITR 505 (SC) (c) Isha Beevi V. TRO [1975] 101 ITR 449 (SC) 7. Ld. CIT(A) finally confirmed the penalty orders passed by ld. AO by following observations : “ In view of the above factual and legal position in the matter, the penalties imposed u/s 271(1)(b) for refusal, without reasonable cause, to furnish the information sought and to execute the consent…

Sh. Manish Periwal, Kolkata vs. DCIT, New Delhi

In the result, assessee’s appeals are dismissed

ITA 5161/DEL/2014[2011-12]Status: PendingITAT Delhi08 Jun 2017AY 2011-12

Bench: Sh. Ramesh. P. Tolani & Sh. Prashant Maharishi

For Appellant: NoneFor Respondent: Sh. Rajesh Kumar, Sr. DR
Section 132Section 142Section 142(1)Section 153ASection 271Section 271(1)(b)Section 274

…Sections 271 and 272A.” 6. Ld. CIT(A) in support of his decision relied on following judgments: 7 ITA No. 5157-5162/Del/2014 (Manish Periwal ) (a) Dhakeswari Cotton Mills Ltd. V. CIT [1955] 27 ITR 126 (SC) (b) Estate of Late Rangalal Jajodia V. CIT [1971] 79 ITR 505 (SC) (c) Isha Beevi V. TRO [1975] 101 ITR 449 (SC) 7. Ld. CIT(A) finally confirmed the penalty orders passed by ld. AO by following observations : “ In view of the above factual and legal position in the matter, the penalties imposed u/s 271(1)(b) for refusal, without reasonable cause, to furnish the information sought and to execute the consent…

Sh. Manish Periwal, Kolkata vs. DCIT, New Delhi

In the result, assessee’s appeals are dismissed

ITA 5160/DEL/2014[2010-11]Status: PendingITAT Delhi08 Jun 2017AY 2010-11

Bench: Sh. Ramesh. P. Tolani & Sh. Prashant Maharishi

For Appellant: NoneFor Respondent: Sh. Rajesh Kumar, Sr. DR
Section 132Section 142Section 142(1)Section 153ASection 271Section 271(1)(b)Section 274

…Sections 271 and 272A.” 6. Ld. CIT(A) in support of his decision relied on following judgments: 7 ITA No. 5157-5162/Del/2014 (Manish Periwal ) (a) Dhakeswari Cotton Mills Ltd. V. CIT [1955] 27 ITR 126 (SC) (b) Estate of Late Rangalal Jajodia V. CIT [1971] 79 ITR 505 (SC) (c) Isha Beevi V. TRO [1975] 101 ITR 449 (SC) 7. Ld. CIT(A) finally confirmed the penalty orders passed by ld. AO by following observations : “ In view of the above factual and legal position in the matter, the penalties imposed u/s 271(1)(b) for refusal, without reasonable cause, to furnish the information sought and to execute the consent…

Sh. Manish Periwal, Kolkata vs. DCIT, New Delhi

In the result, assessee’s appeals are dismissed

ITA 5159/DEL/2014[2009-10]Status: PendingITAT Delhi08 Jun 2017AY 2009-10

Bench: Sh. Ramesh. P. Tolani & Sh. Prashant Maharishi

For Appellant: NoneFor Respondent: Sh. Rajesh Kumar, Sr. DR
Section 132Section 142Section 142(1)Section 153ASection 271Section 271(1)(b)Section 274

…Sections 271 and 272A.” 6. Ld. CIT(A) in support of his decision relied on following judgments: 7 ITA No. 5157-5162/Del/2014 (Manish Periwal ) (a) Dhakeswari Cotton Mills Ltd. V. CIT [1955] 27 ITR 126 (SC) (b) Estate of Late Rangalal Jajodia V. CIT [1971] 79 ITR 505 (SC) (c) Isha Beevi V. TRO [1975] 101 ITR 449 (SC) 7. Ld. CIT(A) finally confirmed the penalty orders passed by ld. AO by following observations : “ In view of the above factual and legal position in the matter, the penalties imposed u/s 271(1)(b) for refusal, without reasonable cause, to furnish the information sought and to execute the consent…

Sh. Manish Periwal, Kolkata vs. DCIT, New Delhi

In the result, assessee’s appeals are dismissed

ITA 5158/DEL/2014[2008-09]Status: PendingITAT Delhi08 Jun 2017AY 2008-09

Bench: Sh. Ramesh. P. Tolani & Sh. Prashant Maharishi

For Appellant: NoneFor Respondent: Sh. Rajesh Kumar, Sr. DR
Section 132Section 142Section 142(1)Section 153ASection 271Section 271(1)(b)Section 274

…Sections 271 and 272A.” 6. Ld. CIT(A) in support of his decision relied on following judgments: 7 ITA No. 5157-5162/Del/2014 (Manish Periwal ) (a) Dhakeswari Cotton Mills Ltd. V. CIT [1955] 27 ITR 126 (SC) (b) Estate of Late Rangalal Jajodia V. CIT [1971] 79 ITR 505 (SC) (c) Isha Beevi V. TRO [1975] 101 ITR 449 (SC) 7. Ld. CIT(A) finally confirmed the penalty orders passed by ld. AO by following observations : “ In view of the above factual and legal position in the matter, the penalties imposed u/s 271(1)(b) for refusal, without reasonable cause, to furnish the information sought and to execute the consent…

Sh. Manish Periwal, Kolkata vs. DCIT, New Delhi

In the result, assessee’s appeals are dismissed

ITA 5157/DEL/2014[2007-08]Status: PendingITAT Delhi08 Jun 2017AY 2007-08

Bench: Sh. Ramesh. P. Tolani & Sh. Prashant Maharishi

For Appellant: NoneFor Respondent: Sh. Rajesh Kumar, Sr. DR
Section 132Section 142Section 142(1)Section 153ASection 271Section 271(1)(b)Section 274

…Sections 271 and 272A.” 6. Ld. CIT(A) in support of his decision relied on following judgments: 7 ITA No. 5157-5162/Del/2014 (Manish Periwal ) (a) Dhakeswari Cotton Mills Ltd. V. CIT [1955] 27 ITR 126 (SC) (b) Estate of Late Rangalal Jajodia V. CIT [1971] 79 ITR 505 (SC) (c) Isha Beevi V. TRO [1975] 101 ITR 449 (SC) 7. Ld. CIT(A) finally confirmed the penalty orders passed by ld. AO by following observations : “ In view of the above factual and legal position in the matter, the penalties imposed u/s 271(1)(b) for refusal, without reasonable cause, to furnish the information sought and to execute the consent…

DCIT, New Delhi vs. M/S. Moon Buildtech Pvt. Ltd., New Delhi

In the result, I.T.A. Nos

ITA 416/DEL/2014[2010-11]Status: DisposedITAT Delhi31 Mar 2016AY 2010-11

Bench: Shri J.S. Reddy & Shri Sudhanshu Srivastava

For Appellant: Shri Anil Jain, CAFor Respondent: Ms Nirupma Kotru, CIT DR
Section 132Section 139Section 153C

…, recording of a simple and valid satisfaction for initiation of the proceedings u/s 153C will suffice. 6 I.T.A. Nos. 202, 203, 416/D/2014 Assessment Years: 2009-10, 2010-11 3.4 Hon’ble Supreme Court has held in Estate of Late Rangalal Jajodia v. CIT [1971] 79 ITR 505 that “An assessment proceeding does not cease to be a proceeding under the Act merely by reason of want of notice. It will be a proceeding liable to be challenged and corrected. Similarly, if there is a mistake as to name or there is a misdescription of the name, the proceeding will be liable to be challenged and corrected by giving notice to the…

Estate of Late Rangalal Jajodia v. CIT (79 ITR 505) — Cited in 25 Judgments | BharatTax