International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
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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