Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
