Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Reassessment validity depended on two jurisdictional defects: the sanction under section 151 was held invalid because the escapement figure shifted from Rs. 1,11,37,000 to Rs. 66,13,961 and then to Rs. 27,00,000, showing non-application of mind at the sanction stage. The Tribunal also held that reopening beyond three years was unsustainable because the surviving alleged escapement was below the Rs. 50 lakh threshold required for extended limitation under section 149(1). On these grounds, the reassessment was held untenable and the remaining issues were left open.
Reassessment validity depended on two jurisdictional defects: the sanction under section 151 was held invalid because the escapement figure shifted from Rs. 1,11,37,000 to Rs. 66,13,961 and then to Rs. 27,00,000, showing non-application of mind at the sanction stage. The Tribunal also held that reopening beyond three years was unsustainable because the surviving alleged escapement was below the Rs. 50 lakh threshold required for extended limitation under section 149(1). On these grounds, the reassessment was held untenable and the remaining issues were left open.
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