Tag: approval u/s 151
Notice u/s 148 quashed as passed without application of mind for quoting wrong section while seeking approval for reopening u/s 151 of the Act – SLP dismissed In a recent judgment, Hon’ble Supreme Court has upheld the judgment of Bombay High Court quashing the order quashing order passed …
ITAT followed recent decision of High Court to held that approval u/s 151 by JCIT by merely recording as ‘yes’ was bad in law. In a recent order, ITAT Delhi following a recent decision of the High Court held that approval u/s 151 by JCIT by merely recording …
Mere use of expression “Yes, I am satisfied” cannot be considered to be a valid approval u/s 148 – High Court In a recent judgment, the Hon’ble Delhi Court has held that the mere use of expression “Yes, I am satisfied” for issuance of notice under Section 148 …
PCIT approval for reopening was without application of mind as despite response it said no reply was submitted by the assesse u/s 148A(b) of the Act In a recent judgment, Hon’ble Allahabad High Court has quashed order u/s 148A(d) and notice issued u/s 148 observing that PCIT approval …
Issue of notice u/s 148 before approval by CIT is void ab initio- Supreme Court dismissed SLP In a recent judgment, Hon’ble Supreme Court dismissed the Special Leave Petition of the Revenue against the judgment that Issue of notice u/s 148 before grant of approval by CIT was …
Reopening notice after 4 year when escaped income less than 1 lakh is time barred and not tenable in the eyes of law – ITAT ABCAUS Case Law Citation: ABCAUS 2608 (2018) (11) ITAT Important Case Laws Cited/relied upon: Amarnath Agrawal vs. CIT & Anr. (2015) 371 ITR …
Reopening us 147 after four years with Addl CIT approval bad. Notice u/s 148 was illegal as approval/satisfaction of CCIT/CIT was required u/s 151(1) – ITAT ABCAUS Case Law Citation: ABCAUS 1188 (2017) (03) ITAT The Ground of Appeal: The effective grounds contested by the assessee was that …