Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
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Validity of reopening of assessment - Sanction for issue of notice u/s 151 - The High Court found that the AO had acted based on borrowed satisfaction and lacked independent application of mind. Additionally, the court ruled that the approval granted was merely mechanical and did not involve proper consideration. Consequently, the court upheld the decision of the ITAT to quash the reopening proceedings and notice issued under Section 148 of the Act, dismissing the appeal of the Revenue.
Validity of reopening of assessment - Sanction for issue of notice u/s 151 - The High Court found that the AO had acted based on borrowed satisfaction and lacked independent application of mind. Additionally, the court ruled that the approval granted was merely mechanical and did not involve proper consideration. Consequently, the court upheld the decision of the ITAT to quash the reopening proceedings and notice issued under Section 148 of the Act, dismissing the appeal of the Revenue.
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