Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
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Signed approval by the prescribed authority is a jurisdictional precondition to issuing a reassessment notice and safeguards against arbitrary reopening. The approving authority must record satisfaction, after considering the recorded reasons and supporting material, through a manual or digital signature. A DIN, electronic transmission, or printed officer name and designation may establish authenticity but cannot replace the required signature. A curative provision introduced after the relevant approval cannot validate the defect. An unsigned approval therefore cannot confer reassessment jurisdiction, rendering consequential reassessment action unsustainable.
Signed approval by the prescribed authority is a jurisdictional precondition to issuing a reassessment notice and safeguards against arbitrary reopening. The approving authority must record satisfaction, after considering the recorded reasons and supporting material, through a manual or digital signature. A DIN, electronic transmission, or printed officer name and designation may establish authenticity but cannot replace the required signature. A curative provision introduced after the relevant approval cannot validate the defect. An unsigned approval therefore cannot confer reassessment jurisdiction, rendering consequential reassessment action unsustainable.
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