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...
Reopening of assessment failed because the sanction under section 151 was mechanical and not granted with application of mind by the competent authority. The approving authority merely recorded that it was a fit case for issuing notice under section 148, without proper particulars such as the date of approval or any meaningful consideration of the proposal. Following settled law that such perfunctory approval is invalid, the ITAT held that the statutory precondition for reopening was not met. Accordingly, the entire reassessment proceedings were quashed.
Reopening of assessment failed because the sanction under section 151 was mechanical and not granted with application of mind by the competent authority. The approving authority merely recorded that it was a fit case for issuing notice under section 148, without proper particulars such as the date of approval or any meaningful consideration of the proposal. Following settled law that such perfunctory approval is invalid, the ITAT held that the statutory precondition for reopening was not met. Accordingly, the entire reassessment proceedings were quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
