Related-party creditor exclusion bars CoC participation where lender rights show policy-making involvement, and post-CIRP assignment cannot cure ineli...
Rectification of apparent typographical errors may proceed without hearing when tax liability, input tax credit, and ruling substance remain unchanged...
Search-derived material for an assessment year covered by Explanation 2 to section 148 requires use of the special reassessment mechanism under sections 147 and 148. A pending scrutiny proceeding initiated by notice under section 143(2) cannot be completed under section 143(3) where that mechanism applies, because the special regime overrides regular scrutiny. Prior approval under section 148B is mandatory; administrative or supervisory approval under a CBDT instruction does not satisfy that requirement. The assessment for AY 2022-23 was quashed on both grounds, without adjudication of additions on merits.
Search-derived material for an assessment year covered by Explanation 2 to section 148 requires use of the special reassessment mechanism under sections 147 and 148. A pending scrutiny proceeding initiated by notice under section 143(2) cannot be completed under section 143(3) where that mechanism applies, because the special regime overrides regular scrutiny. Prior approval under section 148B is mandatory; administrative or supervisory approval under a CBDT instruction does not satisfy that requirement. The assessment for AY 2022-23 was quashed on both grounds, without adjudication of additions on merits.
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