Proportionate interest, unexplained credits and partner remuneration disputed; proofs of fund nexus and lender identity were decisive and disallowance...
Capital gains valuation from stamp assessment versus net consideration for residential reinvestment: deemed stamp value replaced for gains but not for...
Reopening assessments beyond three years requires prior approval from the specified authority; approval must be from PCCIT or PDGIT, or if none exist, from CCIT or DGIT under the procedural mandate, and failure to obtain such specified-authority sanction renders notices issued under section 148 void for want of jurisdiction. The procedural requirements of Section 151 are mandatory and cannot be satisfied by any other officers concurrence; accordingly, a notice issued without the prescribed specified-authority approval is invalid and liable to be quashed, resulting in relief to the taxpayer.
Reopening assessments beyond three years requires prior approval from the specified authority; approval must be from PCCIT or PDGIT, or if none exist, from CCIT or DGIT under the procedural mandate, and failure to obtain such specified-authority sanction renders notices issued under section 148 void for want of jurisdiction. The procedural requirements of Section 151 are mandatory and cannot be satisfied by any other officers concurrence; accordingly, a notice issued without the prescribed specified-authority approval is invalid and liable to be quashed, resulting in relief to the taxpayer.
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