Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Absence of reasons in approval order u/s 151 for reopening assessment u/s 148 renders it invalid. Mere appending of word "approved" without recording satisfaction after application of mind is insufficient. Approval is a safeguard, not a mere ritual, and reasons linking material to conclusion are necessary per Supreme Court's decision in M.L. Capoor's case. Principal Chief Commissioner's grant of approval in printed format without reasons fails to fulfil requirement of Section 151. Mere use of "approval" without independent application of mind cannot be considered valid approval.
Absence of reasons in approval order u/s 151 for reopening assessment u/s 148 renders it invalid. Mere appending of word "approved" without recording satisfaction after application of mind is insufficient. Approval is a safeguard, not a mere ritual, and reasons linking material to conclusion are necessary per Supreme Court's decision in M.L. Capoor's case. Principal Chief Commissioner's grant of approval in printed format without reasons fails to fulfil requirement of Section 151. Mere use of "approval" without independent application of mind cannot be considered valid approval.
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