Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
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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