Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Reopening of assessment u/s 147 - validity of order passed u/s 148A(d) - With Regard to the approval under Section 151 of the Income Tax Act, the High Court questions the decision-making process of the Principal Commissioner of Income Tax (PCIT). Despite the petitioner's objections to the accuracy of the information, the PCIT granted approval, indicating a potential lapse in due diligence or application of mind. - The court suggests that the CIT should have either declined approval or directed the Assessing Officer to address the petitioner's concerns adequately. - The court quashes and sets aside the impugned order and notice.
Reopening of assessment u/s 147 - validity of order passed u/s 148A(d) - With Regard to the approval under Section 151 of the Income Tax Act, the High Court questions the decision-making process of the Principal Commissioner of Income Tax (PCIT). Despite the petitioner's objections to the accuracy of the information, the PCIT granted approval, indicating a potential lapse in due diligence or application of mind. - The court suggests that the CIT should have either declined approval or directed the Assessing Officer to address the petitioner's concerns adequately. - The court quashes and sets aside the impugned order and notice.
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