Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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A reassessment notice issued after expiry of three years from the end of the relevant assessment year required sanction from the higher specified authority under section 151(ii); approval from the Principal Commissioner was insufficient. The Tribunal held that section 151 distinguishes between notices within three years and those issued later, and non-compliance with the correct sanction requirement goes to jurisdiction. The notice under section 148 was therefore invalid, and the assessment framed pursuant to it was quashed.
A reassessment notice issued after expiry of three years from the end of the relevant assessment year required sanction from the higher specified authority under section 151(ii); approval from the Principal Commissioner was insufficient. The Tribunal held that section 151 distinguishes between notices within three years and those issued later, and non-compliance with the correct sanction requirement goes to jurisdiction. The notice under section 148 was therefore invalid, and the assessment framed pursuant to it was quashed.
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