Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Personal hearing requirements in GST adjudication were satisfied by prior opportunities and written submissions; appellate limitation received writ-pe...
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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