Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
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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