Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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