Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
Unsigned approval under section 151 for reassessment was treated as invalid because section 282A(1) requires electronic tax documents to be signed. Following its earlier rulings, the ITAT held that this signature requirement is mandatory; where the approval bore no signature, it was void ab initio. As the foundational approval itself was unlawful, the reassessment proceedings based on it could not survive and the assessment was unsustainable.
Unsigned approval under section 151 for reassessment was treated as invalid because section 282A(1) requires electronic tax documents to be signed. Following its earlier rulings, the ITAT held that this signature requirement is mandatory; where the approval bore no signature, it was void ab initio. As the foundational approval itself was unlawful, the reassessment proceedings based on it could not survive and the assessment was unsustainable.
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