Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
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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