Transitional tax credit for eligible dealers survives incorrect form entries, while previously available eligibility objections cannot be raised on ap...
Reassessment sanction based on an incorrect limitation clause and escaped-income threshold is mechanical and lacks application of mind, invalidating the notice and consequential reassessment. Valid sanction under section 151 is a condition precedent to issuing a notice under section 148. Section 149(1)(b) applies to reopening beyond three years where escaped income in the specified form amounts, or is likely to amount, to at least fifty lakh rupees. The alleged escaped income fell below that threshold and within section 149(1)(a), but the proposal and approval invoked section 149(1)(b).
Reassessment sanction based on an incorrect limitation clause and escaped-income threshold is mechanical and lacks application of mind, invalidating the notice and consequential reassessment. Valid sanction under section 151 is a condition precedent to issuing a notice under section 148. Section 149(1)(b) applies to reopening beyond three years where escaped income in the specified form amounts, or is likely to amount, to at least fifty lakh rupees. The alleged escaped income fell below that threshold and within section 149(1)(a), but the proposal and approval invoked section 149(1)(b).
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