Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
Validity of reopening of assessment u/s 147 - The tribunal sided with the assessee on the key issue of the legality of the re-assessment notice under section 148. It was held that the notice was invalid as it was issued without the required sanction from the competent authority as prescribed under section 151(1) of the Act after the expiry of four years from the end of the relevant assessment year. - The ITAT observed that the argument that the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA) extended the time limit for issuing the notice was not applicable in this case.
Validity of reopening of assessment u/s 147 - The tribunal sided with the assessee on the key issue of the legality of the re-assessment notice under section 148. It was held that the notice was invalid as it was issued without the required sanction from the competent authority as prescribed under section 151(1) of the Act after the expiry of four years from the end of the relevant assessment year. - The ITAT observed that the argument that the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA) extended the time limit for issuing the notice was not applicable in this case.
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