Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Transfer-pricing adjustments for the project business segment required fresh consideration in line with the Dispute Resolution Panel's directions, without adjudication of their merits. The ITAT restored this issue to the Transfer Pricing Officer for a lawful fresh determination after hearing the assessee. The arm's length price of intra-group services was also remanded because the Transfer Pricing Officer had accepted that price in a subsequent assessment year; the merits were not decided. The Transfer Pricing Officer must reconsider the issue after providing an opportunity of hearing. The appeals for the relevant assessment years were allowed for statistical purposes.
Transfer-pricing adjustments for the project business segment required fresh consideration in line with the Dispute Resolution Panel's directions, without adjudication of their merits. The ITAT restored this issue to the Transfer Pricing Officer for a lawful fresh determination after hearing the assessee. The arm's length price of intra-group services was also remanded because the Transfer Pricing Officer had accepted that price in a subsequent assessment year; the merits were not decided. The Transfer Pricing Officer must reconsider the issue after providing an opportunity of hearing. The appeals for the relevant assessment years were allowed for statistical purposes.
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