Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
The ITAT allowed the appeal of Assessee X, holding the reassessment proceedings under s.147 invalid due to improper sanction under the new s.151 regime. The notice u/s 148 and order u/s 148A(d), issued beyond three years from the relevant assessment year, required prior approval from higher specified authorities (PCCI/PDGIT/CCIT/DGIT), but were instead sanctioned by the PCIT, contrary to the amended statutory hierarchy. Relying on binding precedents of the SC and the jurisdictional HC, and holding that TOLA only extended limitation and did not alter the approval structure under s.151, the ITAT quashed the notice u/s 148 and consequently annulled the reassessment order. The assessee's appeal was allowed in full.
The ITAT allowed the appeal of Assessee X, holding the reassessment proceedings under s.147 invalid due to improper sanction under the new s.151 regime. The notice u/s 148 and order u/s 148A(d), issued beyond three years from the relevant assessment year, required prior approval from higher specified authorities (PCCI/PDGIT/CCIT/DGIT), but were instead sanctioned by the PCIT, contrary to the amended statutory hierarchy. Relying on binding precedents of the SC and the jurisdictional HC, and holding that TOLA only extended limitation and did not alter the approval structure under s.151, the ITAT quashed the notice u/s 148 and consequently annulled the reassessment order. The assessee's appeal was allowed in full.
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