Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Reopening of assessment u/s 147 - absence of valid approval to be obtained u/s 151 - The Appellate Tribunal noted that the approval obtained from the Additional Commissioner of Income Tax was not in accordance with the provisions of Section 151, which required approval from a higher authority after the lapse of four years from the relevant assessment year. Therefore, the Tribunal quashed the reassessment order on the grounds of the lack of valid approval, thereby allowing the appeal of the assessee.
Reopening of assessment u/s 147 - absence of valid approval to be obtained u/s 151 - The Appellate Tribunal noted that the approval obtained from the Additional Commissioner of Income Tax was not in accordance with the provisions of Section 151, which required approval from a higher authority after the lapse of four years from the relevant assessment year. Therefore, the Tribunal quashed the reassessment order on the grounds of the lack of valid approval, thereby allowing the appeal of the assessee.
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