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...
Reassessment under section 148A requires the AO to verify the information, disclose the material and inquiry results to the assessee, consider the reply, and record a reasoned view before reopening. Where the notice was based on vague Investigation Wing inputs alleging bogus purchases, without identifying the disputed invoices or supplying supporting material, the Tribunal found no independent application of mind and held the reopening bad in law. On the merits, the assessee produced GST returns, bills, e-way bills, lorry receipts, ledger and bank evidence, while corresponding sales were accepted; in the absence of any defect or proof of grey-market sourcing, the addition for unexplained expenditure was deleted.
Reassessment under section 148A requires the AO to verify the information, disclose the material and inquiry results to the assessee, consider the reply, and record a reasoned view before reopening. Where the notice was based on vague Investigation Wing inputs alleging bogus purchases, without identifying the disputed invoices or supplying supporting material, the Tribunal found no independent application of mind and held the reopening bad in law. On the merits, the assessee produced GST returns, bills, e-way bills, lorry receipts, ledger and bank evidence, while corresponding sales were accepted; in the absence of any defect or proof of grey-market sourcing, the addition for unexplained expenditure was deleted.
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