Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
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Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
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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