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 of assessment under the new regime requires prior sanction by a specified senior authority where reassessment is sought after three years; if income escaping assessment is below the Rs.50,00,000 threshold, no reassessment notice may be issued after three years. Here the alleged escaped income was Rs.10,25,756 and the notice was issued beyond three years with approval only from the Principal Commissioner, which does not meet the prescribed sanctioning requirement; the ITAT held the section 148 notice and consequent reassessment proceedings invalid and quashed them, allowing the assessee's appeal.
Reopening of assessment under the new regime requires prior sanction by a specified senior authority where reassessment is sought after three years; if income escaping assessment is below the Rs.50,00,000 threshold, no reassessment notice may be issued after three years. Here the alleged escaped income was Rs.10,25,756 and the notice was issued beyond three years with approval only from the Principal Commissioner, which does not meet the prescribed sanctioning requirement; the ITAT held the section 148 notice and consequent reassessment proceedings invalid and quashed them, allowing the assessee's appeal.
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