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...
Mandatory pre-show cause intimation under Rule 142(1)(A) was not issued before initiation of the assessment proceedings, and that fact was undisputed. Applying the earlier Division Bench ruling on the same point, the HC held that such non-compliance vitiates the assessment order and requires it to be set aside. The impugned assessment for the relevant financial year was accordingly quashed, and the matter was remanded for fresh assessment in accordance with law, subject to deposit of 20% of the disputed tax within the time granted.
Mandatory pre-show cause intimation under Rule 142(1)(A) was not issued before initiation of the assessment proceedings, and that fact was undisputed. Applying the earlier Division Bench ruling on the same point, the HC held that such non-compliance vitiates the assessment order and requires it to be set aside. The impugned assessment for the relevant financial year was accordingly quashed, and the matter was remanded for fresh assessment in accordance with law, subject to deposit of 20% of the disputed tax within the time granted.
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