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...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
ITAT quashed additions made under section 153A for AY 2013-14 to 2015-16 due to absence of incriminating material found during search proceedings. The Tribunal emphasized that in unabated assessments, additions require supporting incriminating evidence discovered during search. Additionally, the approval granted under section 153D was deemed invalid as Additional CIT failed to demonstrate proper application of mind, merely providing symbolic approval without substantive review. The approval memo revealed delegation of statutory duty to subordinate AO, contrary to legal requirements. Following Abhisar Buildwell precedent, ITAT invalidated the assessment orders, holding them legally unsustainable due to procedural defects in both search-based additions and supervisory approval process.
ITAT quashed additions made under section 153A for AY 2013-14 to 2015-16 due to absence of incriminating material found during search proceedings. The Tribunal emphasized that in unabated assessments, additions require supporting incriminating evidence discovered during search. Additionally, the approval granted under section 153D was deemed invalid as Additional CIT failed to demonstrate proper application of mind, merely providing symbolic approval without substantive review. The approval memo revealed delegation of statutory duty to subordinate AO, contrary to legal requirements. Following Abhisar Buildwell precedent, ITAT invalidated the assessment orders, holding them legally unsustainable due to procedural defects in both search-based additions and supervisory approval process.
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