Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Reassessment initiated after three years from the end of the relevant assessment year required approval from the authority specified in section 151(ii). The Finance Act 2023 proviso to section 151, effective from 1 April 2023, operated prospectively and could not be treated as retrospective merely as a clarification. Extensions or exclusions under section 149 could not be imported into section 151 to extend the three-year period. As sanction under section 151 is a jurisdictional condition precedent, approval by the Principal Commissioner instead of the specified competent authority rendered the notice, order under section 148A(d), and consequential reassessment proceedings void ab initio and liable to be quashed.
Reassessment initiated after three years from the end of the relevant assessment year required approval from the authority specified in section 151(ii). The Finance Act 2023 proviso to section 151, effective from 1 April 2023, operated prospectively and could not be treated as retrospective merely as a clarification. Extensions or exclusions under section 149 could not be imported into section 151 to extend the three-year period. As sanction under section 151 is a jurisdictional condition precedent, approval by the Principal Commissioner instead of the specified competent authority rendered the notice, order under section 148A(d), and consequential reassessment proceedings void ab initio and liable to be quashed.
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