Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
For reassessment notices issued more than three years after the relevant assessment year, prior approval for the order under section 148A(d) and notice under section 148 must come from the authority specified in section 151(ii): the Principal Chief Commissioner, Principal Director General, Chief Commissioner or Director General. Approval by a Principal Commissioner is not valid sanction after that period because that authority lacks statutory competence. A later provision characterising approvals as administrative and supervisory does not cure sanction granted by an unauthorised authority. Reassessment initiated on such invalid approval is liable to be quashed for lack of jurisdiction, while unrelated merits issues remain open.
For reassessment notices issued more than three years after the relevant assessment year, prior approval for the order under section 148A(d) and notice under section 148 must come from the authority specified in section 151(ii): the Principal Chief Commissioner, Principal Director General, Chief Commissioner or Director General. Approval by a Principal Commissioner is not valid sanction after that period because that authority lacks statutory competence. A later provision characterising approvals as administrative and supervisory does not cure sanction granted by an unauthorised authority. Reassessment initiated on such invalid approval is liable to be quashed for lack of jurisdiction, while unrelated merits issues remain open.
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