Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
ITAT held that the reassessment proceedings initiated under s.147 and notice issued under s.148 are invalid because the Pr. CIT's approval under s.151(2) was a mechanical, non-application of mind endorsement. Relying on controlling High Court precedent that condemns perfunctory sanctions evidenced by mere recorded satisfaction, the Tribunal found the sanction to reopen was vitiated. Consequentially, the s.148 notice was held bad in law and the consequent reassessment order was quashed. The appeal by the assessee was allowed and the reassessment proceedings set aside.
ITAT held that the reassessment proceedings initiated under s.147 and notice issued under s.148 are invalid because the Pr. CIT's approval under s.151(2) was a mechanical, non-application of mind endorsement. Relying on controlling High Court precedent that condemns perfunctory sanctions evidenced by mere recorded satisfaction, the Tribunal found the sanction to reopen was vitiated. Consequentially, the s.148 notice was held bad in law and the consequent reassessment order was quashed. The appeal by the assessee was allowed and the reassessment proceedings set aside.
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TaxTMI 
TaxTMI 
of 4886 
