Prospective valuation amendment limits reassessment: unamended fair market value reference could not justify reopening based on a registered valuer's ...
Exemption for examination-related services rejected where recipients were commercial entities; suppression sustained extended limitation and penalties...
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ITAT held the assessment u/s 153A invalid due to procedural defects in approval u/s 153D. The tribunal found the approval was granted mechanically without proper application of mind, as the approving authority lacked access to relevant assessment records and seized materials. Consequently, the assessment order dated 15.03.2016 was quashed as legally unsustainable. The appellate authority set aside the lower court's orders, effectively allowing the assessee's appeal and invalidating the assessment proceedings based on fundamental procedural irregularities in the approval process.
ITAT held the assessment u/s 153A invalid due to procedural defects in approval u/s 153D. The tribunal found the approval was granted mechanically without proper application of mind, as the approving authority lacked access to relevant assessment records and seized materials. Consequently, the assessment order dated 15.03.2016 was quashed as legally unsustainable. The appellate authority set aside the lower court's orders, effectively allowing the assessee's appeal and invalidating the assessment proceedings based on fundamental procedural irregularities in the approval process.
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