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...
Reopening of assessment u/s 147 - valid approval u/s 151 - “unsigned approval” issued in electronic form - The point of time when the AO issued notices u/s 148, he was having no jurisdiction to issue the impugned notices under section 148 of the Act, 1961. Consequently the impugned notices issued by the AO u/s 148 were without jurisdiction. The questions no. (a) and (b) are answered accordingly. - HC
Reopening of assessment u/s 147 - valid approval u/s 151 - “unsigned approval” issued in electronic form - The point of time when the AO issued notices u/s 148, he was having no jurisdiction to issue the impugned notices under section 148 of the Act, 1961. Consequently the impugned notices issued by the AO u/s 148 were without jurisdiction. The questions no. (a) and (b) are answered accordingly. - HC
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