Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
A reassessment notice issued beyond three years from the end of the relevant assessment year required prior approval from the higher authority specified under section 151(ii), not the Principal Commissioner. As the sanction was obtained from an incompetent authority, the approval was invalid and contrary to law. The Tribunal treated this defect as fatal and quashed both the reassessment notice and the consequential assessment order.
A reassessment notice issued beyond three years from the end of the relevant assessment year required prior approval from the higher authority specified under section 151(ii), not the Principal Commissioner. As the sanction was obtained from an incompetent authority, the approval was invalid and contrary to law. The Tribunal treated this defect as fatal and quashed both the reassessment notice and the consequential assessment order.
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