Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Validity of Assessment u/s 153C - Reopening of assessment u/s 147 - In view of such glaring fact covering huge racket of providing accommodation entries of issuing bogus bills, the ld. CIT (Appeals) being conscious of his powers and his authority in directing the ld. Assessing Officer to issue notice under Section 147/148 - CIT-A in guiding the AO giving a direction to proceed u/s 147-148 of the act are in conformity with the income tax act, the direction itself does not prohibit or curtail upon any power of the assessing officer mentioned in those sections, it is in conformity with the provisions of the law and by merely giving this directions the assessee is not aggrieved at all as he has all the rights vested in the income tax act to challenge such action of the assessing officer as and when taken. - AT
Validity of Assessment u/s 153C - Reopening of assessment u/s 147 - In view of such glaring fact covering huge racket of providing accommodation entries of issuing bogus bills, the ld. CIT (Appeals) being conscious of his powers and his authority in directing the ld. Assessing Officer to issue notice under Section 147/148 - CIT-A in guiding the AO giving a direction to proceed u/s 147-148 of the act are in conformity with the income tax act, the direction itself does not prohibit or curtail upon any power of the assessing officer mentioned in those sections, it is in conformity with the provisions of the law and by merely giving this directions the assessee is not aggrieved at all as he has all the rights vested in the income tax act to challenge such action of the assessing officer as and when taken. - AT
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