Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
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Statutory sanction by the authority specified under section...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdiction.
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Statutory sanction by the authority specified under section 151(ii) is a jurisdictional precondition for reassessment notices issued beyond three years where alleged escaped income exceeds the prescribed threshold. For AY 2016-17, approval from the Principal Commissioner did not satisfy the requirement for approval from the Principal Chief Commissioner. The defect invalidated the assumption of reassessment jurisdiction, resulting in the reassessment order being quashed.
Statutory sanction by the authority specified under section 151(ii) is a jurisdictional precondition for reassessment notices issued beyond three years where alleged escaped income exceeds the prescribed threshold. For AY 2016-17, approval from the Principal Commissioner did not satisfy the requirement for approval from the Principal Chief Commissioner. The defect invalidated the assumption of reassessment jurisdiction, resulting in the reassessment order being quashed.
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