Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
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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