Transitional tax credit for eligible dealers survives incorrect form entries, while previously available eligibility objections cannot be raised on ap...
Reassessment requires prior sanction from the authority specified under section 151, determined by the time elapsed from the end of the relevant assessment year. For assessment year 2016-17, the TOLA extension permitted sanction by the Principal Commissioner only until 30 June 2021; sanction in July 2022 required the Principal Chief Commissioner or Chief Commissioner. Sanction by the competent authority is a condition of jurisdiction, and its absence invalidates the section 148A(d) order and section 148 notice without being curable under section 292B. The later proviso could not validate the earlier sanction. A jurisdictional challenge may be raised before the Tribunal as an additional ground when it is a pure question of law based on undisputed facts already on record.
Reassessment requires prior sanction from the authority specified under section 151, determined by the time elapsed from the end of the relevant assessment year. For assessment year 2016-17, the TOLA extension permitted sanction by the Principal Commissioner only until 30 June 2021; sanction in July 2022 required the Principal Chief Commissioner or Chief Commissioner. Sanction by the competent authority is a condition of jurisdiction, and its absence invalidates the section 148A(d) order and section 148 notice without being curable under section 292B. The later proviso could not validate the earlier sanction. A jurisdictional challenge may be raised before the Tribunal as an additional ground when it is a pure question of law based on undisputed facts already on record.
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