Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
The Delhi High Court examined the validity of assessments u/s 153A and whether the specified authority granted approval in accordance with Section 153D. The court emphasized that approval u/s 153D must be granted for "each assessment year" and "each assessee" separately. Referring to a decision by the Allahabad High Court, it was highlighted that the approval process cannot be a mere formality but requires a genuine application of mind. The court noted that in the case at hand, a single approval was granted for multiple assessment years without individual scrutiny, raising concerns about the lack of independent assessment. Upholding the ITAT's decision, the court stressed the importance of thorough assessments and independent consideration for each assessment year.
The Delhi High Court examined the validity of assessments u/s 153A and whether the specified authority granted approval in accordance with Section 153D. The court emphasized that approval u/s 153D must be granted for "each assessment year" and "each assessee" separately. Referring to a decision by the Allahabad High Court, it was highlighted that the approval process cannot be a mere formality but requires a genuine application of mind. The court noted that in the case at hand, a single approval was granted for multiple assessment years without individual scrutiny, raising concerns about the lack of independent assessment. Upholding the ITAT's decision, the court stressed the importance of thorough assessments and independent consideration for each assessment year.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
