Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Reopening of assessment u/s 147 - order u/s 148(A)(d) was passed by respondent without obtaining prior approval of specified authority, i.e. Principal Chief Commissioner of Income Tax, but ex post facto approval was obtained after passing order u/s 148(A)(d). Statutory requirement of prior approval met as Principal Chief Commissioner granted approval same day order passed u/s 148(A)(d). Notice issued u/s 148(A)(b) and order passed u/s 148(A)(d) found valid. Writ petition dismissed.
Reopening of assessment u/s 147 - order u/s 148(A)(d) was passed by respondent without obtaining prior approval of specified authority, i.e. Principal Chief Commissioner of Income Tax, but ex post facto approval was obtained after passing order u/s 148(A)(d). Statutory requirement of prior approval met as Principal Chief Commissioner granted approval same day order passed u/s 148(A)(d). Notice issued u/s 148(A)(b) and order passed u/s 148(A)(d) found valid. Writ petition dismissed.
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