Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
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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