Human-probability test defeats political donation deductions where banking records mask accommodation-entry fund layering rather than genuine contribu...
Sanction for reassessment beyond three years under section 149(1)(b) required valid approval. The approval proforma placed the proceedings within the period exceeding three years but not exceeding ten years, while the approval was granted by the PCIT. Applying a materially similar High Court ruling, ITAT treated the approval as invalid, quashed the section 148A(d) order, section 148 notice and consequential assessment, and left the remaining grounds open as academic.
Sanction for reassessment beyond three years under section 149(1)(b) required valid approval. The approval proforma placed the proceedings within the period exceeding three years but not exceeding ten years, while the approval was granted by the PCIT. Applying a materially similar High Court ruling, ITAT treated the approval as invalid, quashed the section 148A(d) order, section 148 notice and consequential assessment, and left the remaining grounds open as academic.
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