Promissory note presumption of consideration survives blank-signature and income-tax non-disclosure objections when admissions and attesting evidence ...
Charitable registration cancellation: limitation and jurisdiction upheld, but withdrawal quashed under discontinued provisions for skill-development e...
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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