Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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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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