Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
HC held that the specified authority for approval under Section 151 depends on whether the reassessment notice under Section 148 was issued within three years from the end of the relevant assessment year. The court consistently interpreted that the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act (TOLA) extension does not impact the determination of the mandatory approval authority. Based on this legal principle, the court set aside the impugned notice, thereby allowing the assessee's appeal and invalidating the reassessment proceedings due to procedural non-compliance with Section 151 approval requirements.
HC held that the specified authority for approval under Section 151 depends on whether the reassessment notice under Section 148 was issued within three years from the end of the relevant assessment year. The court consistently interpreted that the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act (TOLA) extension does not impact the determination of the mandatory approval authority. Based on this legal principle, the court set aside the impugned notice, thereby allowing the assessee's appeal and invalidating the reassessment proceedings due to procedural non-compliance with Section 151 approval requirements.
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