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...
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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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