Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
ITAT held that reassessment proceedings were invalid where the notice dated 19-07-2022 for A.Y. 2016-17 was issued beyond the three-year period without prior sanction from the authority specified under section 151 of the Act. Because the requisite sanction should have been accorded by the Principal Chief Commissioner or Principal Director General (or, in their absence, Chief Commissioner or Director General), the notice issued with approval only of the Principal Commissioner was vitiated for lack of competent prior approval. The Tribunal allowed the appellant's appeal, quashed the reassessment notice and set aside consequential proceedings as without jurisdiction.
ITAT held that reassessment proceedings were invalid where the notice dated 19-07-2022 for A.Y. 2016-17 was issued beyond the three-year period without prior sanction from the authority specified under section 151 of the Act. Because the requisite sanction should have been accorded by the Principal Chief Commissioner or Principal Director General (or, in their absence, Chief Commissioner or Director General), the notice issued with approval only of the Principal Commissioner was vitiated for lack of competent prior approval. The Tribunal allowed the appellant's appeal, quashed the reassessment notice and set aside consequential proceedings as without jurisdiction.
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