Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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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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