Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Additions based on documents seized in the case of another person must be brought within the reassessment framework under Explanation 2 to section 148, after recording the prescribed satisfaction and obtaining statutory approval; they cannot be made in a regular assessment under section 143(3). The ITAT held that the Assessing Officer's use of third-party search material without following that mandatory procedure rendered the assessment invalid. The assessment order was therefore quashed, and the remaining grounds became academic.
Additions based on documents seized in the case of another person must be brought within the reassessment framework under Explanation 2 to section 148, after recording the prescribed satisfaction and obtaining statutory approval; they cannot be made in a regular assessment under section 143(3). The ITAT held that the Assessing Officer's use of third-party search material without following that mandatory procedure rendered the assessment invalid. The assessment order was therefore quashed, and the remaining grounds became academic.
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