Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Reopening of assessment u/s 147 - AO failed to get the approval u/s 151 - this omission vitiates the reassessment proceedings, notice u/s 148 of the Act and consequent reassessment order dated 05.12.2016 being bad in law and without assuming valid jurisdiction by the AO as per the mandate of section 151 of the Act. - AT
Reopening of assessment u/s 147 - AO failed to get the approval u/s 151 - this omission vitiates the reassessment proceedings, notice u/s 148 of the Act and consequent reassessment order dated 05.12.2016 being bad in law and without assuming valid jurisdiction by the AO as per the mandate of section 151 of the Act. - AT
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