Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
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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