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...
For a non-searched person, the relevant date for determining the block period and search year under section 153C is the date on which seized material is received by the Assessing Officer having jurisdiction over that person, not the date of search in the searched person's case. On that basis, an assessment for the search-related year must be made, if at all, under section 153C read with section 153A; framing it under section 143(3) is a fatal jurisdictional defect. The impugned assessment for Assessment Year 2017-18 was therefore treated as without jurisdiction.
For a non-searched person, the relevant date for determining the block period and search year under section 153C is the date on which seized material is received by the Assessing Officer having jurisdiction over that person, not the date of search in the searched person's case. On that basis, an assessment for the search-related year must be made, if at all, under section 153C read with section 153A; framing it under section 143(3) is a fatal jurisdictional defect. The impugned assessment for Assessment Year 2017-18 was therefore treated as without jurisdiction.
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