Transfer of going concern and transfer of input tax credit under GST allowed; exemption applies though interstate ledger transfers left to authorities...
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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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