Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Grandfathering proviso to Section 149(1)(b) preserves pre-amendment limitation computation for searches after 31.03.2021, so the amended ten-year reopening limit does not retrospectively extend time to reopen years already barred under the old regime; applying that principle the Tribunal found AY 2012-13 time barred. Section 148B is pari materia with prior law and requires prior approval founded on independent application of mind with year-wise appraisal of seized material; mechanical or omnibus approvals without examination of seized material vitiate the approval and render resultant assessments void, leading to quashing of assessments for the affected years.
Grandfathering proviso to Section 149(1)(b) preserves pre-amendment limitation computation for searches after 31.03.2021, so the amended ten-year reopening limit does not retrospectively extend time to reopen years already barred under the old regime; applying that principle the Tribunal found AY 2012-13 time barred. Section 148B is pari materia with prior law and requires prior approval founded on independent application of mind with year-wise appraisal of seized material; mechanical or omnibus approvals without examination of seized material vitiate the approval and render resultant assessments void, leading to quashing of assessments for the affected years.
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