Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Reopening of assessment beyond three years under section 147 was challenged on the ground of invalid sanction under section 151. The Tribunal held that where the notice under section 148 is issued after three years, mandatory approval must be obtained from the Pr. CCIT; approval by the PCIT does not satisfy section 151 and vitiates the assumption of jurisdiction. Consequently, the section 148 notice was held void ab initio, and the reassessment order and the first appellate order were quashed, resulting in allowance of the appeal. - ITAT
Reopening of assessment beyond three years under section 147 was challenged on the ground of invalid sanction under section 151. The Tribunal held that where the notice under section 148 is issued after three years, mandatory approval must be obtained from the Pr. CCIT; approval by the PCIT does not satisfy section 151 and vitiates the assumption of jurisdiction. Consequently, the section 148 notice was held void ab initio, and the reassessment order and the first appellate order were quashed, resulting in allowance of the appeal. - ITAT
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