Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
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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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