Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
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ITAT adjudicated a tax assessment reopening dispute, holding the notice under Section 148 invalid. The AO's notice exceeded statutory time limitations, with escaped income (Rs. 32,92,746) falling below the Rs. 50 lakh threshold required for extended reassessment. Furthermore, the approval was improperly granted by the Principal Commissioner, who lacks jurisdictional authority under Section 151(ii). Consequently, the tribunal set aside the reassessment notice, finding procedural violations in both time limitations and approval process. The assessee's appeal was allowed, effectively nullifying the attempted tax reassessment.
ITAT adjudicated a tax assessment reopening dispute, holding the notice under Section 148 invalid. The AO's notice exceeded statutory time limitations, with escaped income (Rs. 32,92,746) falling below the Rs. 50 lakh threshold required for extended reassessment. Furthermore, the approval was improperly granted by the Principal Commissioner, who lacks jurisdictional authority under Section 151(ii). Consequently, the tribunal set aside the reassessment notice, finding procedural violations in both time limitations and approval process. The assessee's appeal was allowed, effectively nullifying the attempted tax reassessment.
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