In the result, the appeal of the assessee in ITANo
Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal
reassessment proceedings being by way of a safeguard in public interest so that the finally concluded proceedings are not reopened lightly with consequent hardship to the assessee, therefore, these conditions are mandatory conditions; that there could not be a waiver of a mandatory provision and these conditions need to be necessarily fulfilled for exercise of valid jurisdiction; that an order