COMMISSIONER OF INCOME TAX vs. PAWAN GUPTA

The appeals are dismissed

reassessment could never be waived for the simple reason that jurisdiction could neither be waived nor 2009:DHC:1436-DB section 7(2) was a condition precedent to the exercise of jurisdiction to make the best judgment assessment, the doctrine of waiver could never confer jurisdiction so as to enable the parties to avoid the effect of violating a mandatory

RAJAN GUPTA vs. COMMISSIONER OF INCOME TAX

The appeal is allowed as aforesaid