Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
Prior approval of the specified authority is a condition precedent for issuance of notice under section 148, and where more than three years have elapsed from the end of the relevant assessment year, the approval must come from the authority prescribed under section 151(ii). As the approval for the section 148A(d) order was obtained from the Principal Commissioner instead of the competent authority, the reassessment initiation was jurisdictionally defective. The Tribunal held that this non-compliance vitiated jurisdiction and rendered the notice under section 148 void ab initio. Accordingly, the notice, the consequential reopening proceedings, and the reassessment order were quashed.
Prior approval of the specified authority is a condition precedent for issuance of notice under section 148, and where more than three years have elapsed from the end of the relevant assessment year, the approval must come from the authority prescribed under section 151(ii). As the approval for the section 148A(d) order was obtained from the Principal Commissioner instead of the competent authority, the reassessment initiation was jurisdictionally defective. The Tribunal held that this non-compliance vitiated jurisdiction and rendered the notice under section 148 void ab initio. Accordingly, the notice, the consequential reopening proceedings, and the reassessment order were quashed.
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