Reassessment sanction under extended limitation required approval from the competent specified authority, invalidating proceedings approved by an inco...
Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
Reassessment notices for AY 2015-16 issued on or after 1 April 2021 were required to be dropped because the extended period did not preserve the power to issue fresh notices after limitation expired. Reassessment is also without jurisdiction where a return filed in response to a reassessment notice before completion is treated as non-existent solely because it was belated and no notice under section 143(2) is issued. For reopening beyond three years, prior approval from the higher specified authority is mandatory; TOLA's time extension does not alter the statutory hierarchy, making approval by the Principal Commissioner insufficient.
Reassessment notices for AY 2015-16 issued on or after 1 April 2021 were required to be dropped because the extended period did not preserve the power to issue fresh notices after limitation expired. Reassessment is also without jurisdiction where a return filed in response to a reassessment notice before completion is treated as non-existent solely because it was belated and no notice under section 143(2) is issued. For reopening beyond three years, prior approval from the higher specified authority is mandatory; TOLA's time extension does not alter the statutory hierarchy, making approval by the Principal Commissioner insufficient.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
