Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Reopening of assessment u/s 147 - absence of valid approval to be obtained u/s 151 - The Appellate Tribunal noted that the approval obtained from the Additional Commissioner of Income Tax was not in accordance with the provisions of Section 151, which required approval from a higher authority after the lapse of four years from the relevant assessment year. Therefore, the Tribunal quashed the reassessment order on the grounds of the lack of valid approval, thereby allowing the appeal of the assessee.
Reopening of assessment u/s 147 - absence of valid approval to be obtained u/s 151 - The Appellate Tribunal noted that the approval obtained from the Additional Commissioner of Income Tax was not in accordance with the provisions of Section 151, which required approval from a higher authority after the lapse of four years from the relevant assessment year. Therefore, the Tribunal quashed the reassessment order on the grounds of the lack of valid approval, thereby allowing the appeal of the assessee.
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