Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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