Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
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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