Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
ITAT determined the assessment order under s.148A(d) for AY 2018-19 was invalid due to improper sanctioning authority approval. The order issued on 06.04.2022 received approval from Principal Commissioner of Income Tax (PCIT) instead of the statutorily required Principal Chief Commissioner of Income Tax (PCCIT), as mandated by s.151 for cases beyond three years from assessment year end. Following precedent in Holiday Developers case, ITAT held that PCCIT approval was mandatory since the order fell outside the three-year window. Consequently, both the s.148A(d) order and subsequent s.148 notice were quashed, ruling in assessee's favor due to jurisdictional defect in sanctioning authority.
ITAT determined the assessment order under s.148A(d) for AY 2018-19 was invalid due to improper sanctioning authority approval. The order issued on 06.04.2022 received approval from Principal Commissioner of Income Tax (PCIT) instead of the statutorily required Principal Chief Commissioner of Income Tax (PCCIT), as mandated by s.151 for cases beyond three years from assessment year end. Following precedent in Holiday Developers case, ITAT held that PCCIT approval was mandatory since the order fell outside the three-year window. Consequently, both the s.148A(d) order and subsequent s.148 notice were quashed, ruling in assessee's favor due to jurisdictional defect in sanctioning authority.
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TaxTMI 
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