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Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Under the new reassessment regime, where the AO's own determination showed alleged escaped income below the prescribed threshold, a notice under section 148 could not be issued after three years from the end of the relevant assessment year. The Tribunal also held that prior approval under section 151 is a jurisdictional precondition and must be obtained from the authority prescribed for the applicable time limit. As the notice was issued beyond the permissible period and without valid compliance with sections 149 and 151, the notice and the resulting reassessment were void in law and were quashed.
Under the new reassessment regime, where the AO's own determination showed alleged escaped income below the prescribed threshold, a notice under section 148 could not be issued after three years from the end of the relevant assessment year. The Tribunal also held that prior approval under section 151 is a jurisdictional precondition and must be obtained from the authority prescribed for the applicable time limit. As the notice was issued beyond the permissible period and without valid compliance with sections 149 and 151, the notice and the resulting reassessment were void in law and were quashed.
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