Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
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...
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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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