Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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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