Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
Equivalent value attachment under money laundering law upheld where received funds were treated as proceeds of crime and prior-acquired property could...
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Mechanical approval for reassessment sanction under section 151, recorded only as "Yes", was held to show no proper application of mind and no statutory due satisfaction. Relying on the coordinate Bench view in Sandhya Sharma, the Tribunal found that such a perfunctory sanction vitiated the assumption of jurisdiction under sections 147/148. The reassessment initiation was therefore bad in law, and the assessment order was quashed on the jurisdictional ground.
Mechanical approval for reassessment sanction under section 151, recorded only as "Yes", was held to show no proper application of mind and no statutory due satisfaction. Relying on the coordinate Bench view in Sandhya Sharma, the Tribunal found that such a perfunctory sanction vitiated the assumption of jurisdiction under sections 147/148. The reassessment initiation was therefore bad in law, and the assessment order was quashed on the jurisdictional ground.
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