Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
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The ITAT held that the AO lacked jurisdiction to reopen assessments for AYs 2012-13 and 2013-14 under section 153C, as no incriminating material was found during the search that could substantiate additions. The tribunal quashed the reassessment orders, finding the jurisdictional fact absent and following the Supreme Court's precedent in DCIT vs U.K. Paints. The statement from a third party was deemed insufficient to draw adverse inferences, and the tribunal directed deletion of additions made under section 69. Consequently, the assessee's appeals were allowed, invalidating the impugned assessment orders.
The ITAT held that the AO lacked jurisdiction to reopen assessments for AYs 2012-13 and 2013-14 under section 153C, as no incriminating material was found during the search that could substantiate additions. The tribunal quashed the reassessment orders, finding the jurisdictional fact absent and following the Supreme Court's precedent in DCIT vs U.K. Paints. The statement from a third party was deemed insufficient to draw adverse inferences, and the tribunal directed deletion of additions made under section 69. Consequently, the assessee's appeals were allowed, invalidating the impugned assessment orders.
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