Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The HC quashed the reassessment notice and consequential proceedings, holding that the reassessment action could not be sustained due to: (1) the alleged escaped income falling below the pecuniary threshold prescribed u/s 149(1)(b) as per the Supreme Court's ruling in Rajeev Bansal; and (2) the approval for reassessment not being granted by the competent authority u/s 151 after the introduction of the extended timelines by the Taxation Laws (Amendment) Act, 2021. The HC allowed the writ petition in favor of the assessee.
The HC quashed the reassessment notice and consequential proceedings, holding that the reassessment action could not be sustained due to: (1) the alleged escaped income falling below the pecuniary threshold prescribed u/s 149(1)(b) as per the Supreme Court's ruling in Rajeev Bansal; and (2) the approval for reassessment not being granted by the competent authority u/s 151 after the introduction of the extended timelines by the Taxation Laws (Amendment) Act, 2021. The HC allowed the writ petition in favor of the assessee.
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