Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
For reassessment notices issued more than three years after the end of the relevant assessment year, prior approval from the higher specified authority under section 151(ii) is a jurisdictional precondition. Approval from the Principal Commissioner under section 151(i) is insufficient where section 151(ii) applies. Applying this requirement to assessment year 2018-19, the section 148 notice and reassessment under sections 147 and 144B were void ab initio because the required approval was not obtained. The appeal was allowed after condoning delay, and the reassessment was quashed.
For reassessment notices issued more than three years after the end of the relevant assessment year, prior approval from the higher specified authority under section 151(ii) is a jurisdictional precondition. Approval from the Principal Commissioner under section 151(i) is insufficient where section 151(ii) applies. Applying this requirement to assessment year 2018-19, the section 148 notice and reassessment under sections 147 and 144B were void ab initio because the required approval was not obtained. The appeal was allowed after condoning delay, and the reassessment was quashed.
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