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 u/s 147 - Sanction granted by the CIT u/s 151 - simply written “Yes I agree” which does not in any manner shed any light as to whether there was any application of mind at all by the Pr.CIT, - When a superior authority is given power by the legislature, to grant sanction to then that power needs to be exercised with due care and circumspection and after due application of mind - reassessment quashed
Reassessment u/s 147 - Sanction granted by the CIT u/s 151 - simply written “Yes I agree” which does not in any manner shed any light as to whether there was any application of mind at all by the Pr.CIT, - When a superior authority is given power by the legislature, to grant sanction to then that power needs to be exercised with due care and circumspection and after due application of mind - reassessment quashed
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