Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
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Validity of reopening of assessment - Time limit for issuing notice - The High Court observed that the proviso to Section 149 was analyzed, concluding that it applied to assessment years before the amendment and incorporated the pre-amended Section 151. However, it did not incorporate the entire pre-amended Section 151 by reference. - Considering the impact of TOLA, the Court found that it extended time limits but was irrelevant to the challenge in the writ petitions. - As the orders and notices lacked approval from the specified authority under clause (ii) of Section 151, they were deemed invalid.
Validity of reopening of assessment - Time limit for issuing notice - The High Court observed that the proviso to Section 149 was analyzed, concluding that it applied to assessment years before the amendment and incorporated the pre-amended Section 151. However, it did not incorporate the entire pre-amended Section 151 by reference. - Considering the impact of TOLA, the Court found that it extended time limits but was irrelevant to the challenge in the writ petitions. - As the orders and notices lacked approval from the specified authority under clause (ii) of Section 151, they were deemed invalid.
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