Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
ITAT held that reassessment jurisdiction was vitiated because the approval for reopening reflected clear non-application of mind. The Assessing Officer's proposal referred to section 147(b), a provision that had ceased to exist, and the sanctioning authority issued only a ritualistic, mechanical approval under section 151 without correcting the obvious errors. On that jurisdictional defect, the reopening was quashed and the assessee's legal grounds were allowed. The merits of the addition were left open and were not adjudicated.
ITAT held that reassessment jurisdiction was vitiated because the approval for reopening reflected clear non-application of mind. The Assessing Officer's proposal referred to section 147(b), a provision that had ceased to exist, and the sanctioning authority issued only a ritualistic, mechanical approval under section 151 without correcting the obvious errors. On that jurisdictional defect, the reopening was quashed and the assessee's legal grounds were allowed. The merits of the addition were left open and were not adjudicated.
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