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...
Validity of reassessment notices under sections 148 and 148A was not examined on merits because the HC followed the Supreme Court's approach in an identical matter after insertion of section 147A. The writ appeals were allowed, the Single Judge's orders were set aside, and the matters were remitted for fresh consideration. The assessees were given liberty to amend the writ petitions to challenge section 147A and any connected or consequential provision, with all rival contentions left open for decision on remand.
Validity of reassessment notices under sections 148 and 148A was not examined on merits because the HC followed the Supreme Court's approach in an identical matter after insertion of section 147A. The writ appeals were allowed, the Single Judge's orders were set aside, and the matters were remitted for fresh consideration. The assessees were given liberty to amend the writ petitions to challenge section 147A and any connected or consequential provision, with all rival contentions left open for decision on remand.
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