Daily Archives: November 25, 2025

Assessment Quashed: Combined Section 153D Approval for Multiple Years Invalid

By | November 25, 2025

Assessment Quashed: Combined Section 153D Approval for Multiple Years Invalid Issue Whether an assessment order passed under Section 153C (consequent to search) is legally valid if the mandatory prior approval under Section 153D was granted by the Joint Commissioner via a single combined letter covering multiple assessment years, rather than granting specific approval for each… Read More »

Reopening Quashed: Change of Opinion & Mechanical Approval Invalidates Section 148 Notice

By | November 25, 2025

Reopening Quashed: Change of Opinion & Mechanical Approval Invalidates Section 148 Notice Issue Whether the reopening of a completed scrutiny assessment under Section 147/148 is valid when: The transaction in question (payments to M/s Mili Exim Pvt. Ltd.) was specifically verified and accepted in the original assessment, amounting to a mere “change of opinion.” The… Read More »

Warning: Ignoring Income Tax Mismatch Notice May Result in a Tax Demand

By | November 25, 2025

Warning: Ignoring Income Tax Mismatch Notice May Result in a Tax Demand   Issue: To inform taxpayers about the increased volume of system-generated intimations under Section 143(1)(a) of the Income Tax Act and to warn them of the serious financial and compliance consequences of failing to respond to these notices or correct the discrepancies. Facts:… Read More »

Invoice Value Applies for Supply to Related Persons Eligible for ITC (Sri Lakshmi Ganesh Cement and Iron General Stores, AAR Andhra Pradesh)

By | November 25, 2025

Invoice Value Applies for Supply to Related Persons Eligible for ITC (Sri Lakshmi Ganesh Cement and Iron General Stores, AAR Andhra Pradesh) Issue: To determine the correct valuation method under the Goods and Services Tax (GST) Act for goods supplied by a registered person to a related person (a firm owned by the applicant’s wife)… Read More »