Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Absence of reasons in approval order u/s 151 for reopening assessment u/s 148 renders it invalid. Mere appending of word "approved" without recording satisfaction after application of mind is insufficient. Approval is a safeguard, not a mere ritual, and reasons linking material to conclusion are necessary per Supreme Court's decision in M.L. Capoor's case. Principal Chief Commissioner's grant of approval in printed format without reasons fails to fulfil requirement of Section 151. Mere use of "approval" without independent application of mind cannot be considered valid approval.
Absence of reasons in approval order u/s 151 for reopening assessment u/s 148 renders it invalid. Mere appending of word "approved" without recording satisfaction after application of mind is insufficient. Approval is a safeguard, not a mere ritual, and reasons linking material to conclusion are necessary per Supreme Court's decision in M.L. Capoor's case. Principal Chief Commissioner's grant of approval in printed format without reasons fails to fulfil requirement of Section 151. Mere use of "approval" without independent application of mind cannot be considered valid approval.
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