Profiteering in construction services for failure to pass input tax credit resulted in repayment exceeding the commensurate benefit and closure of pro...
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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