Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Reopening of assessment u/s 147 was invalid due to procedural irregularities. The Assessing Officer initiated proceedings without verifying information and the Commissioner of Income Tax granted approval without applying mind. Approval by Commissioner was without recording independent satisfaction, rendering reopening unsustainable. Consequently, notice u/s 148 and subsequent proceedings were quashed. The Commissioner of Income Tax (Appeals) erroneously passed order regarding Vivad Se Vishwas Scheme despite assessee not applying for immunity, hence order quashed. The Assessing Officer made addition without invoking any provision of law or specifying head of income, violating principles of natural justice by denying assessee opportunity to defend. Supreme Court rulings mandate providing reasonable notice of charges and provisions violated. Absence of such notice vitiated proceedings. Therefore, addition made by authorities was deleted and appeal allowed.
Reopening of assessment u/s 147 was invalid due to procedural irregularities. The Assessing Officer initiated proceedings without verifying information and the Commissioner of Income Tax granted approval without applying mind. Approval by Commissioner was without recording independent satisfaction, rendering reopening unsustainable. Consequently, notice u/s 148 and subsequent proceedings were quashed. The Commissioner of Income Tax (Appeals) erroneously passed order regarding Vivad Se Vishwas Scheme despite assessee not applying for immunity, hence order quashed. The Assessing Officer made addition without invoking any provision of law or specifying head of income, violating principles of natural justice by denying assessee opportunity to defend. Supreme Court rulings mandate providing reasonable notice of charges and provisions violated. Absence of such notice vitiated proceedings. Therefore, addition made by authorities was deleted and appeal allowed.
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