Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
A reassessment notice issued under section 148 beyond three years from the end of the relevant assessment year required prior approval from the PCCIT under section 151(ii). Approval from the PCIT was insufficient because the controlling date for identifying the competent sanctioning authority is the date of issue of the section 148 notice. Sanction obtained at the section 148A stage could not replace the separate approval required for issuance of the reopening notice. The Tribunal therefore treated the notice as invalid and quashed the consequential reassessment.
A reassessment notice issued under section 148 beyond three years from the end of the relevant assessment year required prior approval from the PCCIT under section 151(ii). Approval from the PCIT was insufficient because the controlling date for identifying the competent sanctioning authority is the date of issue of the section 148 notice. Sanction obtained at the section 148A stage could not replace the separate approval required for issuance of the reopening notice. The Tribunal therefore treated the notice as invalid and quashed the consequential reassessment.
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