Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
For reassessment notices issued more than three years after the end of the relevant assessment year, section 151(ii) requires approval from the statutorily specified authority rather than the Principal Commissioner. The notes state that the later proviso to section 151, effective from 1 April 2023 and allowing exclusion of time permitted for a reply under section 148A(b), operates prospectively and does not validate an earlier notice. Approval by an incompetent authority is a jurisdictional defect, not a defect in form, authentication or communication curable under section 292BC. On that basis, the reassessment for AY 2018-19 was quashed, with other contentions left open.
For reassessment notices issued more than three years after the end of the relevant assessment year, section 151(ii) requires approval from the statutorily specified authority rather than the Principal Commissioner. The notes state that the later proviso to section 151, effective from 1 April 2023 and allowing exclusion of time permitted for a reply under section 148A(b), operates prospectively and does not validate an earlier notice. Approval by an incompetent authority is a jurisdictional defect, not a defect in form, authentication or communication curable under section 292BC. On that basis, the reassessment for AY 2018-19 was quashed, with other contentions left open.
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