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...
ITAT held that reassessment jurisdiction was vitiated because the approval for reopening reflected clear non-application of mind. The Assessing Officer's proposal referred to section 147(b), a provision that had ceased to exist, and the sanctioning authority issued only a ritualistic, mechanical approval under section 151 without correcting the obvious errors. On that jurisdictional defect, the reopening was quashed and the assessee's legal grounds were allowed. The merits of the addition were left open and were not adjudicated.
ITAT held that reassessment jurisdiction was vitiated because the approval for reopening reflected clear non-application of mind. The Assessing Officer's proposal referred to section 147(b), a provision that had ceased to exist, and the sanctioning authority issued only a ritualistic, mechanical approval under section 151 without correcting the obvious errors. On that jurisdictional defect, the reopening was quashed and the assessee's legal grounds were allowed. The merits of the addition were left open and were not adjudicated.
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