Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
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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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