Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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Delay of 294 days in filing Special Leave Petition deemed invalid. Reopening of assessment u/s 143(3) without proper sanction u/s 151(1) from competent authority. Income Tax Officer obtained satisfaction from Additional Commissioner, an authority not covered by Section 151(1). Writ petition under Article 226 maintainable due to non-fulfillment of pre-conditions for exercise of power u/s 148. Application seeking condonation of delay dismissed by Supreme Court due to unsatisfactory explanation, consequently dismissing Special Leave Petition on ground of delay.
Delay of 294 days in filing Special Leave Petition deemed invalid. Reopening of assessment u/s 143(3) without proper sanction u/s 151(1) from competent authority. Income Tax Officer obtained satisfaction from Additional Commissioner, an authority not covered by Section 151(1). Writ petition under Article 226 maintainable due to non-fulfillment of pre-conditions for exercise of power u/s 148. Application seeking condonation of delay dismissed by Supreme Court due to unsatisfactory explanation, consequently dismissing Special Leave Petition on ground of delay.
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