Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
The article addresses two dominant legal conditions for valid...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below threshold.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
The article addresses two dominant legal conditions for valid reassessment notices: first, the substituted reassessment regime mandates prior sanction by the specific higher authority defined in section 151 before issuing a notice under section 148 where more than three years have elapsed, and absence of that prescribed approval renders the notice void; second, section 149(1)(b) restricts reassessment beyond three years to cases where escaped income meets the statutory monetary threshold, and an alleged escape below that threshold bars issuance of a notice. Applying both principles, the notice was void and reassessment was set aside.
The article addresses two dominant legal conditions for valid reassessment notices: first, the substituted reassessment regime mandates prior sanction by the specific higher authority defined in section 151 before issuing a notice under section 148 where more than three years have elapsed, and absence of that prescribed approval renders the notice void; second, section 149(1)(b) restricts reassessment beyond three years to cases where escaped income meets the statutory monetary threshold, and an alleged escape below that threshold bars issuance of a notice. Applying both principles, the notice was void and reassessment was set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
